Standard of Proof for Juveniles: Reasonable Doubt v. Preponderance

Kids grow up quickly.

One day, they’re taking their first steps. The next, they’re getting busted for heroin distribution and beating the government in the Sixth Circuit Court of Appeals.

(Ideally, a parent captures more of the former and less of the latter in scrapbooks, but who can ever forget a kid’s first vacated sentence?)

The Sixth Circuit Court of Appeals vacated a juvenile offender's sentence this week, finding that a district court applied the wrong standard of proof when sentencing the teen.

CTH was 16 years old when arrested for possession of heroin with intent to distribute it near a Speedway gas station in Flint, Michigan. CTH pled guilty to an act of juvenile delinquency, and the district court held a sentencing hearing. It found by a preponderance of the evidence that CTH was responsible for the distribution of 647 grams of heroin, and sentenced him to five years' official detention.

While the Sentencing Guidelines typically do not apply to juveniles, they factored into CTH's sentence thanks to a "quirk" in the federal juvenile-delinquency statute. The statute provides that the maximum period of a juvenile's official detention is the lesser of five years or "the maximum of the guideline range" applicable to an otherwise similarly-situated adult defendant. Up to that ceiling, any fact that increases the guidelines maximum for a similarly-situated adult serves to increase the statutory-maximum period of official detention for the juvenile.

Absent the 647 gram finding, the guidelines maximum for a similarly-situated adult might have been as low as 12 months. With the finding, the maximum period of detention -- and CTH's actual sentence -- was 60 months.

CTH argued to the Sixth Circuit Court of Appeals that the government should have been required to prove the drug quantity beyond a reasonable doubt, rather than just by a preponderance, because it was a fact that increased the statutory-maximum period of his official detention. The Sixth Circuit, citing Apprendi v. New Jersey, agreed and vacated the sentence.

Even though juvenile proceedings provide a different context than adult criminal trials, the Sixth Circuit ruled that Apprendi supports the proposition that the standard of proof for any fact that increases a juvenile's statutory-maximum term of official detention is reasonable doubt.

Related Resources:

• U.S. v. CTH (FindLaw's CaseLaw)
• Apprendi v. New Jersey (FindLaw's CaseLaw)
• Legal to Sentence Juvenile to Death Penalty? (FindLaw's Blotter)