Juvenile Adjudications Can Count as "Prior Conviction" and Enhance Sentencing Under Federal Law
United States v. Jones, 332 F.3d 688 (3d Cir. 2003); 72(1) U.S. Law Week 1003-04 (July 8, 2003)
The Third Circuit ruled a juvenile adjudication can count as a "prior conviction" for purposes of enhancing sentencing under federal law if the adjudication was based on a proceeding that included the privilege against self incrimination and rights to notice, counsel, confrontation, and proof beyond a reasonable doubt. The court determined the absence of a right to a jury trial in the juvenile proceeding was not dispositive because a bench trial provided sufficient reliability to the outcome. In so ruling, the court agreed with the Eighth Circuit but disagreed with the Ninth...