Appellant
Samuel Winship
Appellee
State of New York
Appellant's Claim
That his conviction of a crime in a juvenile delinquency proceeding was unconstitutional because the state did not prove that he committed the crime beyond a reasonable doubt
Chief Lawyer for Appellant
Rena K. Uviller
Chief Lawyer for Appellee
Stanley Buchsbaum
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., (writing for the Court), WilliamO. Douglas, John Marshall Harlan II, Thurgood Marshall, Byron R. White
Justices Dissenting
Hugo Lafayette Black, Warren E. Burger, Potter Stewart
Place
Washington, D.C.
Date of Decision
31 March 1970
Decision
That the criminal law standard requiring proof of a crime beyond a reasonabledoubt is a constitutional requirement, and it applies equally to adults andjuveniles.
Significance
The Court's decision made clear that juveniles accused of crimes are entitledto the same constitutional protections as adults facing criminal convictions. The Court's decision also elevated the general criminal law rule that the prosecution must prove every element of a crime beyond a reasonable doubt to arule of constitutional law. Thus, following the Court's decision, the prosecutor in the criminal case bears a heavy burden in proving that the defendantcommitted the crime.
The 1950s and 1960s were a time of great activity for the U.S. Supreme Court.During this era, generally referred to as the "Rights Revolution," the Courtexpanded greatly the constitutional rights of criminal defendants. Decisionsduring this time recognized that a defendant has the right to a court appointed attorney, to be informed of his right to remain silent, and to be questioned by the police only in the presence of an attorney. In Winship, theCourt added to these rights the right to be convicted only where the prosecution proves each element of the criminal offense beyond a reasonable doubt, and expanded this right to juveniles accused of a crime in a juvenile delinquency proceeding.
In 1967, Samuel Winship, who was 12 years old at the time, stole $112 from apurse in a locker. He was charged in the New York Family Court as being a juvenile delinquent. Under New York law at the time, a juvenile delinquent included any person between the ages of seven and 16 who committed an act which, if done by an adult, would be a crime. Any juvenile found to be delinquent could be placed in a juvenile detention center until his eighteenth birthday. Relying on the New York law, the family court judge found that Winship was a juvenile delinquent by a "preponderance of the evidence." The "preponderance ofthe evidence" standard is much easier to meet than the reasonable doubt standard, and requires only that it is more likely than not that the defendant committed the crime. Put another way, under the preponderance of the evidence standard, the jury need only be 51 percent sure that the defendant committed the crime, whereas under the reasonable doubt standard the jury would have tobe a least 95 percent sure that the defendant committed the crime.
Winship then appealed his conviction to the New York Court of Appeals, arguing that the Due Process Clause of the Fourteenth Amendment required the prosecution to prove that he committed the crime he was charged with beyond a reasonable doubt. The Due Process Clause provides that a state may not deprive a person of "life, liberty or property without due process of law." The SupremeCourt has interpreted the Due Process Clause to require a state to afford a number of protections to criminal defendants. The New York Court of Appeals rejected Winship's argument that one of these protections is the right to proofbeyond a reasonable doubt before being convicted. Winship appealed this decision to the U.S. Supreme Court.
Due Process Requires Proof Beyond a Reasonable Doubt
The central question before the Court was whether the Constitution required that a defendant be convicted only upon proof beyond a reasonable doubt that he committed the crime. In the 1967 case In re Gault, the Court held that when a juvenile is accused of a crime in a juvenile delinquency proceeding, he need not be given all the rights that an adult has in a criminal trial.However, a juvenile must be given "the essentials of due process and fair treatment." Thus, the question in Winship was whether the requirement ofproof beyond a reasonable doubt is essential to "due process and fair treatment." The Court concluded that it is an integral part of due process.
The Court first noted that the reasonable doubt standard in criminal cases had been followed by nearly every state, the federal government, and England since the 1700s. The Court reasoned that such a long-standing practice reflectsan historical judgment that the reasonable doubt standard is an integral part of conducting a fair trial. The Court also reasoned that the reasonable doubt standard is important because it is better to have a potentially guilty person go free than to have an innocent person deprived of his liberty:
Having concluded that the reasonable doubt standard is a constitutional requirement to obtaining a valid conviction, the Court went on to hold that the standard also applies in juvenile delinquency proceedings where the juvenile ischarged with a crime. The Court found that the same reasons which support applying the reasonable doubt standard in adult criminal trials also support applying the standard to juveniles accused of a crime.
Creating Rights
In a dissenting opinion, Justice Black accused the Court of creating rights which do not exist in the Constitution. He reasoned that many of the amendments in the Bill of Rights provide for certain rights to criminal defendants, "but nowhere in that document is there any statement that conviction of crime requires proof beyond a reasonable doubt." Justice Black thought that the Court should be guided by the language of the Constitution itself, and should notinterpret "due process" to require whatever the Supreme Court decides is "fair." He concluded that it was up to the state and federal legislatures, and not the Court, to determine what is the appropriate standard of proof in criminal trials, and that due process only requires that the prosecution meet thatlevel of proof chosen by the legislature.
Impact
The Court's decision in Winship was important in two respects. First,it reaffirmed the Court's earlier decision in Gault that juveniles accused of a crime are entitled to the same constitutional protections providedto adults accused of a crime. Second, it clarified that whether in the stateor federal courts, a criminal defendant cannot be convicted unless the prosecution proves his guilt beyond a reasonable doubt.
Related Cases
Samuel Winship
Appellee
State of New York
Appellant's Claim
That his conviction of a crime in a juvenile delinquency proceeding was unconstitutional because the state did not prove that he committed the crime beyond a reasonable doubt
Chief Lawyer for Appellant
Rena K. Uviller
Chief Lawyer for Appellee
Stanley Buchsbaum
Justices for the Court
Harry A. Blackmun, William J. Brennan, Jr., (writing for the Court), WilliamO. Douglas, John Marshall Harlan II, Thurgood Marshall, Byron R. White
Justices Dissenting
Hugo Lafayette Black, Warren E. Burger, Potter Stewart
Place
Washington, D.C.
Date of Decision
31 March 1970
Decision
That the criminal law standard requiring proof of a crime beyond a reasonabledoubt is a constitutional requirement, and it applies equally to adults andjuveniles.
Significance
The Court's decision made clear that juveniles accused of crimes are entitledto the same constitutional protections as adults facing criminal convictions. The Court's decision also elevated the general criminal law rule that the prosecution must prove every element of a crime beyond a reasonable doubt to arule of constitutional law. Thus, following the Court's decision, the prosecutor in the criminal case bears a heavy burden in proving that the defendantcommitted the crime.
The 1950s and 1960s were a time of great activity for the U.S. Supreme Court.During this era, generally referred to as the "Rights Revolution," the Courtexpanded greatly the constitutional rights of criminal defendants. Decisionsduring this time recognized that a defendant has the right to a court appointed attorney, to be informed of his right to remain silent, and to be questioned by the police only in the presence of an attorney. In Winship, theCourt added to these rights the right to be convicted only where the prosecution proves each element of the criminal offense beyond a reasonable doubt, and expanded this right to juveniles accused of a crime in a juvenile delinquency proceeding.
In 1967, Samuel Winship, who was 12 years old at the time, stole $112 from apurse in a locker. He was charged in the New York Family Court as being a juvenile delinquent. Under New York law at the time, a juvenile delinquent included any person between the ages of seven and 16 who committed an act which, if done by an adult, would be a crime. Any juvenile found to be delinquent could be placed in a juvenile detention center until his eighteenth birthday. Relying on the New York law, the family court judge found that Winship was a juvenile delinquent by a "preponderance of the evidence." The "preponderance ofthe evidence" standard is much easier to meet than the reasonable doubt standard, and requires only that it is more likely than not that the defendant committed the crime. Put another way, under the preponderance of the evidence standard, the jury need only be 51 percent sure that the defendant committed the crime, whereas under the reasonable doubt standard the jury would have tobe a least 95 percent sure that the defendant committed the crime.
Winship then appealed his conviction to the New York Court of Appeals, arguing that the Due Process Clause of the Fourteenth Amendment required the prosecution to prove that he committed the crime he was charged with beyond a reasonable doubt. The Due Process Clause provides that a state may not deprive a person of "life, liberty or property without due process of law." The SupremeCourt has interpreted the Due Process Clause to require a state to afford a number of protections to criminal defendants. The New York Court of Appeals rejected Winship's argument that one of these protections is the right to proofbeyond a reasonable doubt before being convicted. Winship appealed this decision to the U.S. Supreme Court.
Due Process Requires Proof Beyond a Reasonable Doubt
The central question before the Court was whether the Constitution required that a defendant be convicted only upon proof beyond a reasonable doubt that he committed the crime. In the 1967 case In re Gault, the Court held that when a juvenile is accused of a crime in a juvenile delinquency proceeding, he need not be given all the rights that an adult has in a criminal trial.However, a juvenile must be given "the essentials of due process and fair treatment." Thus, the question in Winship was whether the requirement ofproof beyond a reasonable doubt is essential to "due process and fair treatment." The Court concluded that it is an integral part of due process.
The Court first noted that the reasonable doubt standard in criminal cases had been followed by nearly every state, the federal government, and England since the 1700s. The Court reasoned that such a long-standing practice reflectsan historical judgment that the reasonable doubt standard is an integral part of conducting a fair trial. The Court also reasoned that the reasonable doubt standard is important because it is better to have a potentially guilty person go free than to have an innocent person deprived of his liberty:
The requirement of proof beyond a reasonable doubt has this vital role in our criminal procedure for cogent reasons. The accused during a criminal prosecution has at stake interest of immense proportions, both because of the possibility that he may lose his liberty upon conviction and because of the certainty that he would be stigmatized by the conviction. Accordingly, a society that values the good name and freedom of every individual should not condemn a man for commission of a crime when there is a reasonable doubt about hisguilt.Thus, the Court held that the reasonable doubt standard isan element of due process required under the Constitution to insure that a defendant receives a fair trial.
Having concluded that the reasonable doubt standard is a constitutional requirement to obtaining a valid conviction, the Court went on to hold that the standard also applies in juvenile delinquency proceedings where the juvenile ischarged with a crime. The Court found that the same reasons which support applying the reasonable doubt standard in adult criminal trials also support applying the standard to juveniles accused of a crime.
Creating Rights
In a dissenting opinion, Justice Black accused the Court of creating rights which do not exist in the Constitution. He reasoned that many of the amendments in the Bill of Rights provide for certain rights to criminal defendants, "but nowhere in that document is there any statement that conviction of crime requires proof beyond a reasonable doubt." Justice Black thought that the Court should be guided by the language of the Constitution itself, and should notinterpret "due process" to require whatever the Supreme Court decides is "fair." He concluded that it was up to the state and federal legislatures, and not the Court, to determine what is the appropriate standard of proof in criminal trials, and that due process only requires that the prosecution meet thatlevel of proof chosen by the legislature.
Impact
The Court's decision in Winship was important in two respects. First,it reaffirmed the Court's earlier decision in Gault that juveniles accused of a crime are entitled to the same constitutional protections providedto adults accused of a crime. Second, it clarified that whether in the stateor federal courts, a criminal defendant cannot be convicted unless the prosecution proves his guilt beyond a reasonable doubt.
Related Cases
- Davis v. United States, 160 U.S. 469 (1895).
- In re Gault, 387 U.S. 1 (1967).
- Cupp v. Naughten, 414 U.S. 141 (1973).
- Mullaney v. Wilbur, 421 U.S. 684 (1975).
- Jackson v. Virginia, 443 U.S. 307 (1979).
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