In Re WINSHIP

25 L. Ed. 2d 368 · Supreme Court of the United States · 1970

Facts

A 12-year-old boy was accused of entering a locker and stealing $112 from a woman's pocketbook. The petition charged him with delinquency, alleging his act would be larceny if committed by an adult. A New York Family Court judge found him delinquent based on a preponderance of the evidence, acknowledging the proof might not establish guilt beyond a reasonable doubt. The boy was then ordered to a training school for an initial 18 months, with potential extensions until his 18th birthday, totaling six years.

Procedural history

A New York Family Court judge found the appellant delinquent based on a preponderance of the evidence. The Appellate Division of the New York Supreme Court, First Judicial Department, affirmed this decision without opinion. The New York Court of Appeals then affirmed by a four-to-three vote, expressly upholding the constitutionality of the preponderance of evidence standard. The U.S. Supreme Court noted probable jurisdiction and reversed the judgment.

Issue

Is proof beyond a reasonable doubt an essential of due process and fair treatment required during the adjudicatory stage when a juvenile is charged with an act that would constitute a crime if committed by an adult?

Holding

The Court reversed the lower court's decision. It held that where a juvenile is charged with an act that could lead to confinement, due process requires the case against him to be proved beyond a reasonable doubt.

Rule

The Due Process Clause protects an accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime charged. This standard is indispensable in criminal procedure to reduce the risk of factual error and protect individuals from the immense importance of losing liberty and being stigmatized. These same considerations apply to juveniles, as civil labels and good intentions do not obviate the need for criminal due process safeguards when a juvenile faces loss of liberty comparable to a felony prosecution.

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