In re Winship
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 of proof 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 reflects an 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 his guilt.Thus, the Court held that the reasonable doubt standard is an 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 is charged 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.
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