Schall v. Martin
**Overview of Schall v. Martin**
Schall v. Martin is a significant Supreme Court case that addressed the issue of preventive detention for juveniles. It emerged from New York State's Family Court Act, which allowed for the detention of juvenile delinquents prior to trial if there was a concern that their release could lead to harm or flight. The case involved several juveniles, including Gregory Martin, who faced serious criminal charges and argued that their detention violated the Fourteenth Amendment's due process clause. The central question was whether such preventive detention constituted punishment without due process.
In a 7-2 decision, the Supreme Court upheld the New York law, concluding that while the due process clause does apply to juveniles, the state's interest in protecting public safety could justify their detention in certain circumstances. Chief Justice William Rehnquist, writing for the majority, indicated that the potential risk to both the juveniles and the community could warrant preventive measures consistent with fundamental fairness. The ruling reflects the complex balance between individual rights and public safety concerns in the juvenile justice system.
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Schall v. Martin
The Case: U.S. Supreme Court ruling on preventive detention
Date: Decided on June 4, 1984
Significance: In agreeing with a New York State family court in this preventive detention case, the Supreme Court limited the application of the Fourteenth Amendment’s due process clause.
Schall v. Martin was a preventive detention case involving juveniles. New York State had enacted a Family Court Act pertaining to juvenile delinquents and to juveniles arrested and remanded to the family court prior to trial. If the family court determined that pretrial release of juveniles might result in their disappearance or place them or the general public at risk, it was authorized to detain them. Detention occurred only after notice was given to parents and other authorities, a hearing was held, a statement of facts and reasons was presented, and “probable cause” that release might be harmful was established.
Juvenile detainees Gregory Martin, Luis Rosario, and Kenneth Morgan (along with thirty-three other juveniles introduced into the case) faced serious charges. Martin had been arrested in 1977, charged with first-degree robbery, second-degree assault, and criminal possession of a gun after he and two others struck another youth on the head with a loaded gun and beat him in order to steal his jacket and sneakers. He was found guilty of these crimes by a family court judge and placed on two years’ probation. Martin was fourteen. Rosario, also fourteen, was charged with robbery and second-degree assault for trying to rob two men by putting a gun to their heads and beating them. He previously had been detained for knifing a student. Morgan, fourteen, had four previous arrests and had been charged with attempted robbery, assault, and grand larceny for robbing and threatening to shoot a fourteen-year-old girl and her brother.
Martin and the others brought suit claiming that their detention deprived them of a writ of habeas corpus and violated the due process clause of the Fourteenth Amendment. The federal district appeals court agreed that their detention “served as punishment without proof of guilt according to requisite constitutional standards.” Gregory Schall, commissioner of the New York City Department of Juvenile Justice, appealed to the Supreme Court. The case reached the Supreme Court at a time when polls showed that crime was a major fear of the American public and when a relatively conservative Court was exercising judicial restraint and limiting the expansion of civil liberties.
Reading the majority 7-2 decision, Justice William Rehnquist acknowledged that the due process clause of the Fourteenth Amendment indeed applied to the pretrial detention of juveniles. He agreed with Schall, however, that when, as in these cases, there was “serious risk” involved to both the juveniles and the public by their release, the New York law was compatible with the “fundamental fairness” demanded by the due process clause.
Bibliography
Champion, Dean John. The Juvenile Justice System: Delinquency, Processing, and the Law. 4th ed. Upper Saddle River, N.J.: Prentice-Hall, 2003.
Cox, Steven M., John J. Conrad, and Jennifer M. Allen. Juvenile Justice: A Guide to Theory and Practice. 5th ed. New York: McGraw Hill, 2003.
Shaughnessy, Edward J. Bail and Preventive Detention in New York. Washington, D.C.: University Press of America, 1982.
Singer, Richard G. Criminal Procedure II: From Bail to Jail. New York: Aspen, 2005.