Schall V. Martin's Impact On The Juvenile Justice System

On June 4, 1984 a significant decision was made in the Supreme Court that is still impacting the juvenile justice system. It may not be as large of a controversy as the death penalty for minors or have as large of an impact as In re Gault, but Schall v. Martin made some large changes to the treatment of juvenile delinquents prior to adjudication. After this decision was rendered, it was established by the Supreme Court that pre-adjudication detention of a juvenile was in fact constitutional and did not go against their due process rights granted in the Bill of Rights. Prior to this decision, juvenile detention centers were very temporary in nature. The average length of stay in the nation was about 15 days and it typically covered the
During his pre-adjudication detention, which only lasted for a total of 15 days, Martin began a habeas corpus class action against the Commissioner of the New York City Department of Juvenile Justice and was joined by 33 others with similar situations. It was argued that pre-adjudication detention was a punishment prior to determination of guilt and therefore in violation of their due process right guaranteed in the Fourteenth Amendment.
The New York Family Court Act established the juvenile system for the state of New York. In the act, there is a provision that allows a brief pre-adjudication detention based on the belief that the arrested juvenile might commit another crime before his adjudication. The stipulation that is made is that the juvenile must be found to be of “serious risk” to commit another crime pre-adjudication and that it is in their best interest as well as the state’s best interest that they be
It was of their opinion that most juvenile petitions were dismissed before any adjudication of delinquency or released immediately after adjudication and that the pre-adjudication detention was ultimately unnecessary. It also concluded that the provision of the Family Court Act was used less as a preventative measure as it was written and more to impose a punishment. The fact that most of the juveniles were released immediately after adjudication contradicted the reasoning given for pre-adjudication detention. They further concluded that the provision must be declared unconstitutional for all juveniles and that individual litigation would be pointless due to the very short durations of