In re Winship
The Court's decision made clear that juveniles accused of crimes are entitled to 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 a rule of constitutional law. Thus, following the Court's decision, the prosecutor in the criminal case bears a heavy burden in proving that the defendant committed 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 Court expanded greatly the constitutional rights of criminal defendants. Decisions during 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, the Court 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 a purse 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 of the 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 to be 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 Supreme Court 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 proof beyond a reasonable doubt before being convicted. Winship appealed this decision to the U.S. Supreme Court.
Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972In re Winship - Significance, Due Process Requires Proof Beyond A Reasonable Doubt, Creating Rights, Further Readings