Bland v. United States

1973-05-21

Headline: Denies review and leaves in place a D.C. law that lets prosecutors charge 16-year-olds as adults, keeping a system that can send juveniles into adult criminal court without a juvenile hearing.

Holding: The Court refused to review the case and denied the petition, leaving intact lower-court rulings that permit prosecutors to charge 16-year-olds as adults under the District of Columbia statute.

Real World Impact:

Allows prosecutors to charge 16-year-olds as adults under D.C. law.
Leaves juveniles subject to adult criminal proceedings without a juvenile hearing.
No Supreme Court ruling on whether that charging power violates due process.

Topics: juvenile justice, prosecutor discretion, due process, criminal procedure

Summary

Background

A 16-year-old was arrested and indicted for an armed robbery of a post office in the District of Columbia. Under a D.C. statute, the United States Attorney can treat a 16-year-old as an adult simply by charging him with certain felonies. The teenager moved to dismiss the indictment, arguing that being charged as an adult without a juvenile hearing denied him fair procedure. The District Court dismissed the charge, and the Court of Appeals reversed that dismissal.

Reasoning

The Supreme Court declined to review the case and simply denied the petition for review. Because the Court refused to take the case, it did not decide the central legal questions on the merits. Justice Douglas (joined by two other Justices) dissented from the denial and argued the Court should have agreed to decide whether the prosecutor’s power to reclassify a juvenile as an adult violates basic fairness and the standards announced in earlier juvenile cases like Kent and Gault. He also raised whether courts can use the Administrative Procedure Act to review prosecutorial decisions that may violate those fairness rules.

Real world impact

The denial leaves the D.C. statutory scheme and the Court of Appeals’ ruling in place. Practically, prosecutors in the District can continue to charge some 16-year-olds as adults without a separate juvenile transfer hearing. Because the Supreme Court did not rule on the merits, the constitutional questions raised remain unresolved and could be taken up in a future case.

Dissents or concurrances

Justice Douglas’s dissent warned that giving such broad charging power to prosecutors risks arbitrary treatment of juveniles and urged judicial review to protect their procedural rights.