Schall v. Martin

Background

A class of youths detained under a New York law challenged the practice. The law, §320.5(3)(b) of the Family Court Act, lets a judge order short pretrial detention when there is a “serious risk” the child may commit a crime before the next court date. The named plaintiffs included a 14‑year‑old arrested for robbery who was detained 15 days and two other 14‑year‑olds detained for shorter periods; the District Court and Second Circuit had struck the statute down.

Reasoning

The Court asked two questions: whether preventive detention serves a legitimate state goal and whether the statute’s procedures protect juveniles’ due‑process rights. The majority held that the statute advances valid state interests — protecting the community and the child — and that the Act provides notice, counsel, a recorded initial appearance, a required statement of reasons, and a formal probable‑cause hearing within three days (with limited short extensions). The Court also noted statutory time limits (maximum about 17 days for designated felonies, six days for lesser offenses) and avenues for state court review.

Real world impact

As a practical matter, the ruling allows Family Court judges to continue using the preventive‑detention procedure in appropriate short‑term cases. Detained juveniles retain expedited hearings and procedural protections under the Act, and state courts and habeas review remain available to challenge particular detentions. The Supreme Court reversed the Second Circuit’s blanket invalidation of the statute.

Dissents or concurrances

The dissent warned that, in practice, many detained youths were first offenders or were later released, that secure detention can resemble jail, and that prediction of future wrongdoing and judicial discretion risk arbitrary or punitive detentions.