Also known as: juvenile adjudications · juvenile adjudicatory hearing
Written by attorneys · grounded in primary & secondary sources — see below
A judicial determination by a juvenile court that a minor has committed an act that would constitute a crime if performed by an adult. The finding carries consequences for the minor's liberty and record but receives distinct treatment under evidence rules and constitutional protections. Federal Rule of Evidence 609(d) limits its use for impeachment to criminal cases involving a witness other than the accused when the underlying offense would be admissible against an adult and admission is necessary to determine guilt or innocence.
Joanna Jung stands trial for smuggling. The prosecution calls 16-year-old Luis, a cabin steward, who testifies that Jung handed him packages. Defense counsel seeks to question Luis about his juvenile adjudication for cabin theft and his current probation to show he may be currying favor with authorities. The court permits the inquiry because the Confrontation Clause requires an opportunity to expose this potential bias.
Jordan Jenkins faces federal fraud charges. The government withholds information that its key witness, a 17-year-old teller, received a juvenile adjudication for account misuse while on probation. The defense moves for a new trial after discovering the omission. The court grants relief because the withheld material could have supported a bias argument and its suppression undermined a fair determination of guilt.
Select any source to read its text and confirm it supports the definition.
James Johnson, age 14, faces a juvenile petition alleging conduct that would be felony tampering if committed by an adult. The state presents only blurry hallway footage and testimony that other students had access to the office. Johnson moves for dismissal at the close of the state's case. The court applies the constitutional standard requiring proof beyond a reasonable doubt of every element before entering an adjudication.
A defendant may cross-examine when the inquiry is necessary to show bias or attack credibility and the witness is not the accused. The Confrontation Clause overrides ordinary protections for juvenile records in such circumstances.
Supporting sources
The evidence must be offered in a criminal case, concern a witness other than the defendant, involve an offense that would be admissible against an adult, and be necessary to fairly determine guilt or innocence.
Supporting sources
Yes. When the petition alleges conduct that would be criminal if committed by an adult, due process demands that the state prove every element beyond a reasonable doubt.
Supporting sources
No. Rule 609(d) expressly bars use of a juvenile adjudication to impeach the defendant even in a criminal case.
Supporting sources
…because he has been found to be a delinquent, or (3) burden the juvenile courts with a procedural requirement that will make juvenile adjudications significantly more time consuming, or rigid. Today's decision simply requires a juvenile court judge to be more confident in his belief that the youth did the act with which he has been…