Schall v. Martin

The ruling settled the dispute over whether preventive detention of juveniles, considered likely to engage in further crime prior to their trials, serves a legitimate state objective. The state successfully argued that its system of procedural protections satisfied requirements of the Due Process Clause of the Fourteenth Amendment. As highlighted by the dissenting opinion, the need for substantially reforming the nation's juvenile court systems became widely recognized. Both the proponents of tougher punishment and advocates for a juvenile rehabilitation emphasis sought to reduce the informal arbitrariness of juvenile judicial decisions by providing more structured sentencing guides. The practice of detaining juveniles received increased public support during a period of rising youth violence in the 1990s.

In the late 1970s, the New York Family Court Act allowed short term detention (confinement) of accused juveniles prior to having their cases resolved. Under normal procedures, following arrest of a juvenile, a probation officer would determine if the case should go to juvenile court based on an interview with the juvenile and the arresting officer. If so, an "initial appearance" hearing was held next. There a judge determined if preventive detention was justified based on whether the juvenile was at "serious risk" to commit more offenses prior to a final hearing. A formal consideration of specific facts in the case was not required. If detained, the juvenile was entitled to as many as two more hearings within 14 days after the initial appearance for serious crimes, three days for lesser offenses. The maximum potential detention time for serious offenses was 17 days, for others it was six. Juveniles were kept separate from adult criminals and screened to determine whether non-secure or secure detention facilities were appropriate. Both included educational and recreational programs and counseling by social workers.

Between December of 1977 and March of 1978, police arrested three 14-year old juveniles, Gregory Martin, Luis Rosario, and Kenneth Morgan, in three separate incidents on a variety of charges including robbery, assault, and possession of a loaded gun. Given their ages, they came within jurisdiction of New York's Family Court. Martin, detained for 15 days between arrest and resolution of his case, was found guilty and placed on two years probation. Rosario, who had other assault charges pending, was detained for six days. His case was later dropped. Morgan, who also had charges pending from another incident, was detained for eight days. He was found guilty and placed in custody for 18 months.

While in detention, Martin filed a suit on behalf of all similarly detained juveniles challenging the legality of preventive detention. Joined later by Rosario and Morgan in the suit, Martin claimed pretrial detention violated the Due process and Equal Protection Clauses of the Fourteenth Amendment. Due Process guarantees each individual fairness before the law in legal proceedings. Equal Protection essentially requires that a law be a reasonable means of achieving a government objective. The U.S. District Court accepted the case.

During the trial both sides provided case histories of over 30 individuals including general statistics on the relation between pretrial detention and how the cases were ultimately resolved. Testimony also centered on general juvenile court processes. After weighing the evidence, the district court ruled the Family Court Act did not violate the Equal Protection Clause, but did violate due process. The district court ordered the release of all detained juveniles. The state appealed to the U.S. Court of Appeals which affirmed the district court decision. The appeals court found that "the vast majority of juveniles detained" are ultimately released after their cases were heard. Therefore, the detention served more as a punishment for untried juveniles than a prevention of additional crime. The lack of any significant confinement after their trials contradicted any claimed need for pretrial confinement for community protection. Consequently, the court determined the process was unconstitutional toward all juveniles.