Schall v. Martin

Facts of the Case

Gregory Martin was arrested on Dec. 13, 1977 and charged with first-degree robbery, second-degree assault, and criminal possession of a weapon based on an incident in which he, with two others, allegedly hit a youth on the head with a loaded gun and stole his jacket and sneakers. Martin had possession of the gun when he was arrested. He was 14 years old at the time and came within the jurisdiction of New York’s Family Court. The incident occurred at 11:30 PM and Martin lied to the police about where and with whom he lived. He was consequently detained overnight. A petition of delinquency was filed and Martin made his initial appearance in Family Court on Dec. 14th, accompanied by his grandmother. The family court judge, citing the possession of the loaded weapon, the false address given to the police, and the lateness of the hour, as evidencing a lack of supervision, ordered Martin detained under § 320.5(3)(b). On Dec. 21, 1977, while still in preventive detention pending his fact-finding hearing, Martin brought a habeas corpus class action in the United States District Court for the Southern District of New York for a judgment declaring § 320.5(3)(b) unconstitutional under the due process and equal protection clauses of the Fourteenth Amendment. The district court rejected the equal protection argument as insubstantial, but held that the statute violated the due process clause, and it ordered the release of all class members detained under the statute. The United States Court of Appeals for the Second Circuit affirmed.

Question

Is the pretrial detention of a juvenile delinquent a violation of the right to Due Process as guaranteed in the Fourteenth Amendment if there is a “serious risk” that the juvenile will “commit an act which if committed by an adult would constitute a crime”?

CONCLUSION

No. Justice William H. Rehnquist, writing for a 6-3 majority, held that pretrial detention of juveniles does not violate the right of Due Process. The pretrial detention serves the legitimate purpose of protecting both the state and the juvenile from further crimes. Since the state has more responsibilities in the case of a juvenile than in the case of an adult, the pretrial detention not only protects society from potential crime, but it also protects the juvenile from the potential physical and psychological harm that can happen in the commission of a crime. The Court also found that the FCA put in place enough procedural safeguards that the juveniles are not denied Due Process. They are afforded notice, a hearing, and a statement of facts before any detention takes place, as well as an additional hearing to determine probable cause if the fact-finding hearing is not scheduled within three days.Justice Thurgood Marshall dissented and wrote that the standard of “serious risk” was too vague and easily satisfied given the limited information in the possession of the judge or the juvenile’s lawyer at the time of the initial hearing. Additionally, the conditions of juvenile detention centers are often such that the psychological harms of subjecting a juvenile who has not been found guilty to that environment far outweigh the abstract benefits to society. Given the near-impossibility of predicting whether or not a juvenile will commit a crime in the near future, Justice Marshall found that drastic measures such as pretrial detention could not be justified and represented a violation of Due Process. Justices William J. Brennan, Jr. and John Paul Stevens joined in the dissent.

Case Information

  • Citation: 467 US 253 (1984)
  • Argued: Jan 17, 1984
  • Decided Jun 4, 1984Granted: Apr 18, 1983