The Supreme Court case Kent v. United States, 383 U.S. 541 (1966) raised a number of important issues regarding the treatment of juveniles in the criminal justice system. The facts are as follows. The defendant, Morris A. Kent, Jr. was arrested for breaking into a woman’s apartment, stealing her wallet, and raping her (Kent v. United States, 1966, p. 543). He was 16 years old at the time he committed these offenses and, because of his age, was subject to the exclusive jurisdiction of the juvenile court (Kent v. United States, 1966, p. 543). Kent was subsequently taken into police custody, where he was interrogated extensively. When Kent’s mother became aware of her son’s arrest the following day, she obtained immediate counsel.
Kent’s counsel discussed with possibility of the juvenile court waiving jurisdiction, and counsel made clear his intentions to oppose such a waiver (Kent v. United States, 1966, p. 545). During the hearing to consider whether to grant or deny the waiver, the judge held no hearing, did not confer with Kent, his mother, or his counsel, and without making formal findings and giving no reason for the decision, granted the waiver (Kent v. United States, 1966, p. 546). Kent’s case was then brought in the District Court, where a grand jury indicted him on the charges of housebreaking robbery, and rape (Kent v. United States, 1966, p. 548). Kent made a motion to dismiss the indictment due to an invalid waiver, and the District Court denied the motion to dismiss. At trial, Kent was found guilty of six counts of housebreaking and robbery and was sentenced to 30-90 years imprisonment (Kent v. United States, 1966, p. 550).
The issue before the Supreme Court was whether the waiver of juvenile court jurisdiction, transferring the case to the District Court, was invalid. The Court held that there were many procedural flaws in the way the juvenile court handled the waiver request. The Court noted the significance of the waiver and that it determined “vital important statutory rights of the juvenile” (Kent v. United States, 1966, p. 556). Thus, during the proceedings of a waiver hearing, a juvenile is entitled to certain due process rights, which Kent was not afforded in the instant case. Ultimately, the Court remanded the case for the District Court to conduct a de novo hearing of whether the waiver was appropriate or not.
Whenever a party stands to lose significant rights and freedoms, the “liberty” component of the due process clause applies in full force. It is undeniable that a waiver, which removes a case from the juvenile court to the regular criminal court, has a tremendous impact on the juvenile party’s future. As the Court pointed out, there was a great deal at stake resting on the grant or denial of the juvenile court’s waiver determination. Adjudication in a juvenile court would probably result in a few years imprisonment and some community service, whereas Kent received a 30-90 year sentence in criminal court. A prison sentence of 30-90 years most certainly implicates due process rights.
The juvenile court and the adult criminal court serve distinctly different purposes and functions. A juvenile’s entire life may hinge on whether he is tried in juvenile court or conventional criminal court. The exclusive jurisdiction of the juvenile court over juvenile delinquents reflected the policy of treating juveniles as children rather than as adults. In juvenile court, the court is designed to give special consideration to the youthful age and immaturity of the child. A juvenile, therefore, will receive a much more lenient and rehabilitative sentence if adjudicated in juvenile court as opposed to criminal court.
As the Court aptly pointed out, the parens patriae function of the court is ill served if procedural protections are not respected. A decision that gives no reasons or supporting evidence for its findings should not be allowed to stand if such important rights are at issue. Although it is clear that juvenile courts do not provide for the same due process rights as its criminal court counterpart, the critical decision of whether to waive juvenile court jurisdiction should not be treated in such a blasé, informal manner.
References
Kent v. United States, 383 U.S. 541 (1966).
