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Children and Juvenile Law, Keyed to Feld, 6th Ed.
Schall v. Martin
Citation:
467 U.S. 253, 104 S. Ct. 2403, 81 L. Ed. 2d 207 (1984)Facts
The case involved three juvenile plaintiffs who had been detained under New York’s Family Court Act § 320.5(3)(b). Gregory Martin, age 14, was arrested for robbery and weapons possession after allegedly hitting a youth and stealing his jacket and sneakers. He was detained for 15 days before being adjudicated delinquent and placed on probation. Luis Rosario, age 14, was charged with attempted robbery and assault, and was detained for 27 days before his case was terminated without a finding of delinquency. Kenneth Morgan, age 14, was charged with attempted robbery and attempted grand larceny, and was detained for 8 days before being found guilty of harassment and petit larceny. The plaintiffs brought a class action suit challenging the constitutionality of the detention provision. The District Court found that the statute violated due process because it permitted detention without a probable cause determination, relied on predictions of future criminal behavior that were impossible to make accurately, and functioned as punishment without adjudication. The Court of Appeals affirmed, finding that the statute was primarily used to impose punishment for unadjudicated criminal acts.
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