State v. Cain

Supreme Court of Florida
381 So.2d 1361 (1980)

ELI5:

Sections

Rule of Law:

The legislature may constitutionally grant a state attorney the discretion to prosecute a juvenile as an adult without a judicial hearing, provided the juvenile meets specific statutory criteria regarding age and prior criminal history.

Facts:

Mark Randall Cain, a juvenile, allegedly committed two counts of armed burglary of a dwelling and two counts of grand theft.
Virgil Thomas Duncan, a juvenile, allegedly committed acts constituting petit theft.
At the time of these distinct alleged offenses, both Cain and Duncan were sixteen years of age or older.
Both juveniles had previously committed two delinquent acts, at least one of which involved an offense classified as a felony under Florida law.
These prior records and ages brought both juveniles within the scope of a Florida statute allowing the state attorney to file criminal charges in adult court rather than juvenile court.

Procedural Posture:

In State v. Cain: The State Attorney filed an information charging Cain as an adult.
Cain filed a motion to dismiss, challenging the constitutionality of the statute.
The Circuit Court declared the statute unconstitutional and dismissed the information.
The State appealed the dismissal directly to the Florida Supreme Court.
In Duncan v. State: The Sheriff initially filed a complaint in the juvenile division.
The State Attorney subsequently filed an information in County Court (adult division).
The County Court transferred the case to the juvenile division upon Duncan's motion.
The Circuit Court granted the State's motion to transfer the case back to County Court.
Duncan filed a motion to dismiss in County Court alleging the statute was unconstitutional.
The County Court denied the motion to dismiss.
Duncan pleaded nolo contendere and was adjudicated guilty.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state statute granting the prosecutor discretion to charge juveniles as adults without a judicial waiver hearing violate constitutional guarantees of due process, equal protection, or separation of powers?

Opinions:

Majority - Justice Sundberg

No, the statute is constitutional and the state attorney may exercise discretion to prosecute qualifying juveniles as adults. The Court reasoned that there is no inherent common law or constitutional right for a minor to be treated as a juvenile delinquent; this status is strictly a creation of the legislature. Consequently, the legislature has the power to define exceptions to juvenile jurisdiction. The Court distinguished this case from Kent v. United States, holding that the requirement for a waiver hearing applies only when a judge is making the waiver decision, not when the legislature has vested that discretion in the executive branch (the prosecutor). The prosecutorial discretion to charge a juvenile as an adult is analogous to the traditional, absolute discretion of a prosecutor to decide whom to charge and for what offense. Furthermore, the statute does not violate separation of powers because enforcing laws and making charging decisions are executive functions, and the 'public interest' standard provided in the statute is sufficient guidance.

Analysis:

This decision reinforces the broad power of state legislatures to define the boundaries of the juvenile justice system and the extensive discretion of prosecutors within that system. By validating 'direct file' statutes, the court established that procedural due process rights attached to judicial waiver hearings (as defined in Kent v. United States) do not extend to prosecutorial charging decisions. This effectively treats the decision to charge a youth as an adult as a traditional executive function rather than a judicial adjudication of status. The ruling clarifies that juvenile status is a statutory privilege, not a constitutional right, allowing the state to retract that privilege for repeat offenders based on age and criminal history without a preliminary hearing.

Gunnerbot

AI-powered case assistant

Loaded: State v. Cain (1980)

Try: "What was the holding?" or "Explain the dissent"