Breed v. Jones
Headline: Court barred adult prosecution after a juvenile court adjudication, holding that trying a youth again in adult court violated the Double Jeopardy Clause and protects juveniles from two trials for the same offense.
Holding: The Court held that trying a person in adult court after a juvenile adjudicatory hearing for the same offense violates the Fifth Amendment’s Double Jeopardy protection as applied to the States, barring a second trial.
- Prevents retrying juveniles as adults after juvenile adjudication
- Requires transfer decisions before adjudicatory hearings
- Vacates adult convictions entered after prior juvenile adjudication for same offense
Summary
Background
The case involved a 17-year-old who was accused of armed robbery in Los Angeles. The Juvenile Court held an adjudicatory hearing on March 1 and found the youth had committed the acts alleged. At a later dispositional hearing the Juvenile Court declared him unfit for juvenile treatment and ordered that he be prosecuted in adult court; he was later convicted in Superior Court and then sought habeas relief arguing he had been tried twice for the same offense.
Reasoning
The Court asked whether a juvenile adjudicatory hearing creates the same risk of multiple trials that the Double Jeopardy Clause forbids. It concluded that the adjudicatory hearing is comparable in seriousness and consequence to a criminal trial and that jeopardy attached when the juvenile court began to hear evidence. The Court rejected the State’s argument that the juvenile system’s informality and need for flexibility justify retrying the youth as an adult. It held those policy concerns do not outweigh the constitutional protection against being tried twice for the same offense and explained transfer decisions should normally be made before an adjudicatory hearing.
Real world impact
The Court held that retrying a juvenile in adult court after a juvenile adjudication violates the Double Jeopardy Clause, vacated the adult conviction in this case, and remanded for further proceedings consistent with that ruling. The decision requires that transfer-to-adult decisions generally be made before an adjudicatory hearing so youths are not subjected to two separate trials.
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