North Carolina v. T. D. R.

The ruling recognized flexibility lower state courts have in trying violent juvenile offenders as adults. The case characterized the responsiveness of state governments, including court systems, to public demands for toughening punishment measures of violent and destructive crimes, even when performed by youths.

To many the juvenile justice system had fallen into chaos toward the end of the twentieth century. While violent crime in the United States decreased in general through the 1990s, violent crime by teens rose dramatically. The juvenile court system, originally established to try youths under the age of 18, was increasingly accused of letting violent teen criminals off with nothing more than "a slap on the wrist."

Traditionally, the age of the juvenile and the seriousness of the offense were the key criteria considered when determining whether to try a juvenile as an adult. With respect to age, 21 states had no minimum age requirement for a juvenile to be tried as an adult, and of the remaining 29 states, minimum age requirements ranged from seven to 16 years of age. The primary offenses for which juveniles were tried as adults included the more serious crimes such as murder, offenses involving serious personal injury, property crimes, public order offenses, and drug offenses. Some states tried juveniles as adults if their alleged offense would normally constitute a felony and evidence existed of prior felony convictions. Moreover, some states allowed juveniles to be tried as adults if they were considered unlikely to respond to the treatment available in juvenile detention facilities.

Trying juveniles in the adult court system always sparked heated debate. Fear of random violence committed by young teens became one of the nation's greatest concerns by the late 1990s. Encouraged by the Violent Crime Control and Law Enforcement Act of 1994, many state legislatures enacted "get tough" measures ensuring violent teen offenders would be punished "appropriately" for their crime. Two prominent viewpoints existed in the debate of trying teens as adults. The conservative position maintained that treating teens as adults was an effective way to express public outrage for the offenses of wayward youth by ensuring punishment. The opposing viewpoint contended that trying teens as adults was too harsh. Embracing the motto that "children are the future of this country," juvenile advocates contended that society had a responsibility to rehabilitate youth while plenty of time still existed to lead productive lives. Also, juveniles incarcerated with hardened adult criminals were easy prey for sexual assault and other forms of violence. However, a seeming increase of highly publicized violent crimes committed by the hands of young teens and even pre-teens occurred through the 1990s, including an outbreak of school shootings. The rehabilitation stance gradually lost ground to the more conservative punishment stance to appease the public's outcry for more severe treatment of violent teen offenders.