Michaels v. Arizona

Background

In March 1971 a teenager was arrested after alleged robberies near an elementary school. The youth was charged in Pima County juvenile court with several offenses, including armed robbery, assault with a deadly weapon, and theft. In April 1971 the juvenile court declared the youth delinquent, dismissed the theft count, reduced one robbery to attempted robbery and an assault to simple assault, and placed the youth on indefinite probation. On appeal the Arizona Supreme Court struck some charges as based on identifications tainted by an illegal arrest but affirmed one attempted robbery and the disposition.

Reasoning

The practical question presented was whether the juvenile was entitled to a jury trial and to a judge not involved in prosecutorial supervision. Arizona rules denied a jury trial in juvenile proceedings, and juvenile judges in the State appoint and supervise the prosecutorial staff. The Supreme Court did not reach the constitutional issue: it dismissed the appeal for lack of jurisdiction, treated the filing as a petition for review, and denied review. Because the Court declined to decide the merits, the constitutional claim about jury rights was left unresolved by the majority.

Real world impact

As a result of the dismissal and denial of review, the Arizona juvenile court’s non-jury adjudication stands in this case. The outcome leaves in place a system where juvenile judges who supervise prosecutors preside over delinquency cases, raising concerns about impartial decisionmakers. The ruling is not a final resolution of the constitutional question and could be raised again in future cases.

Dissents or concurrances

Justice Douglas dissented, arguing that juveniles facing possible confinement until majority should not be denied the same jury-trial protections adults receive and that the discrimination against children is unjustified.