Proof of a criminal charge beyond a reasonable doubt is constitutionally required. It is the duty of the government to establish guilt beyond a reasonable doubt. This notion is a requirement and a safeguard of due process of law in the historic, procedural content of due process.
Petitioner appeared on a juvenile's behalf at his adjudicatory proceeding to determine his delinquency. The juvenile had been charged with committing acts that, had they been done by an adult, would have been larceny. The juvenile court made its determination based on a preponderance of the evidence presented, relying on N.Y. Fam. Ct. Act § 744(b), and ordered him to a training school for 1 1/2 years, with possible extensions to his 18th birthday.
Is proof beyond reasonable doubt, which is the standard required for conviction in a criminal prosecution, required to determine juvenile delinquency?
The Supreme Court found the same concerns that led to the establishment of proof beyond a reasonable doubt in criminal matters were no less evident in a juvenile proceeding, and particularly in this case where the juvenile was charged with an act that rendered him liable to confinement for up to six years. The Court rejected respondent city's argument that delinquency adjudications were not convictions and would have no effect on his citizenship rights or privileges. The Court acknowledged the underlying policy of the juvenile justice system was rehabilitation, but that none of the substantive benefits of the juvenile process would be compromised by adopting the higher standard of proof.