685 F.3d 560
6th Cir.2012Background
- CTH, age 16, pled guilty to juvenile delinquency for possession of heroin with intent to distribute near a Flint, Michigan gas station.
- District court held a dispositional hearing and preponderantly found CTH responsible for 647 grams of heroin.
- CTH was sentenced to five years’ official detention under 18 U.S.C. § 5037.
- The statutory-maximum detention for a juvenile depends on the maximum of an adult’s guideline range, up to five years.
- The finding of drug quantity increased the juvenile’s maximum detention; CTH argues this must be proven beyond a reasonable doubt.
- The court vacates the dispositional order and remands for proceedings consistent with this opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether drug quantity increasing the maximum detention must be proven beyond a reasonable doubt. | CTH argues this fact is an element; must be proven beyond a reasonable doubt. | Gov’t contends no jury-right in juvenile adjudication; Apprendi not applicable. | Yes; quantity must be proved beyond a reasonable doubt. |
| Whether Apprendi’s due-process requirement applies to juvenile proceedings. | Winship-based due process requires proof beyond reasonable doubt for all facts that constitute the crime. | Apprendi rationale does not apply due to lack of Sixth Amendment jury right in juveniles. | Apprendi’s due-process holding applies; quantity must be proved beyond a reasonable doubt. |
| Whether Apprendi applies uniformly across juvenile and adult contexts. | Precedents support parity between juvenile and adult due process for element findings. | Apprendi concerns adults; not applicable to juveniles. | The rule applies; juveniles receive the same due-process protection. |
Key Cases Cited
- In re Winship, 397 U.S. 358 (U.S. 1970) (due process requires proof beyond reasonable doubt of every element)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact increasing a crime’s penalty must be proved beyond a reasonable doubt)
- McKeiver v. Pennsylvania, 403 U.S. 528 (U.S. 1971) (juvenile trials need not have a jury; but Apprendi-like justification applies to facts increasing penalties)
- S. Union Co. v. United States, 132 S. Ct. 2344 (S. Ct. 2012) (collects cases applying Apprendi to sentencing schemes)