explaining “[i]t is critical that the moral force of the criminal law not be diluted by a standard of proof that leaves people in doubt whether innocent men are being condemned” and, therefore, “every individual going about his ordinary affairs [must] have confidence that his government cannot adjudge him guilty of a criminal offense without convincing a proper factfinder of his guilt with utmost certainty”
How later courts described this case
- explaining “[i]t is critical that the moral force of the criminal law not be diluted by a standard of proof that leaves people in doubt whether innocent men are being condemned” and, therefore, “every individual going about his ordinary affairs [must] have confidence that his government cannot adjudge him guilty of a criminal offense without convincing a proper factfinder of his guilt with utmost certainty”
- explaining the long-standing history of the government’s burden-of-proof, describing the “vital role [the reasonable-doubt standard plays] in the American scheme of criminal procedure,” and “explicitly hold[ing] that the Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the crime with which he is charged”
- holding that the reasonable doubt standard is “a prime instrument for reducing the risk of convictions resting on factual error. The standard provides concrete substance for the presumption of innocence' — that bedrock axiomatic and elementary principle whose enforcement lies at the foundation of the administration of our criminal law.” (internal quotation marks omitted)
- stating that "[t]he [reasonable-doubt] standard provides concrete substance for the presumption of innocence—that bedrock 'axiomatic and elementary' principle whose 'enforcement lies at the foundation of the administration of our criminal law"' (quoting Coffin v. United States, 156 U.S. 432, 453 (1895))
Written by the judges who cited it.
Later courts went against this
Questioned by Commonwealth v. Rose, 457 Pa. 380 (1974)
While the continuing validity of Leland in light of Winship is questionable,6 our decision need not rest on federal constitutional grounds.
Questioned by People v. Hedgecock, 51 Cal. 3d 395 (1990)
We observed, however, that “the continuing vitality of [this rule] may be doubtful in light of In re Winship [1970] 397 U.S. 358 [25 L.Ed.2d 368, 90 S.Ct. 1068], and Connecticut v. Johnson [1983] 460 U.S. 73 [74 L.Ed.2d 823, 103 S.Ct. 969].
Distinguished
Distinguished by State v. Childress, 169 Wash. App. 523 (2012)
Because, we determined, “[a] declination hearing is not an adjudicatory proceeding,” Winship was inapplicable.
Distinguished by State v. Downs, 51 Ohio St. 2d 47 (1977)
Although the state argued that the defendant would in any event suffer the consequences of a criminal conviction, for Mullaney involved only the degree of punishment, the court was not convinced that Winship was inapplicable.
Distinguished by In Re People in Interest of DS, 502 P.2d 95 (1972)
We reject the contention of the Public Defender that In re Winship, 397 U.S. 358, 90 S.Ct. 1068, 25 L.Ed.2d 368, requires proof beyond a reasonable doubt in juvenile probation revocation hearings.
Distinguished by State v. Henderson, 1972 Iowa Sup. LEXIS 867 (1972)
The facts upon which Winship was based are distinguishable from our case.
The opinion
Mr. Chief Justice Burger,
with whom Mr. Justice Stewart joins,
dissenting.
The Court’s opinion today rests entirely on the assumption that all juvenile proceedings are “criminal prosecutions,” hence subject to constitutional limitations. This derives from earlier holdings, which, like today’s *376 holding, were steps eroding the differences between juvenile courts and traditional criminal courts. The original concept of the juvenile court system was to provide a benevolent and less formal means than criminal courts could provide for dealing with the special and often sensitive problems of youthful offenders. Since I see no constitutional requirement of due process sufficient to overcome the legislative judgment of the States in this area, I dissent from further strait-jacketing of an already overly restricted system. What the juvenile court system needs is not more but less of the trappings of legal procedure and judicial formalism; the juvenile court system requires breathing room and flexibility in order to survive, if it can survive the repeated assaults from this Court.
Much of the judicial attitude manifested by the Court’s opinion today and earlier holdings in this field is really a protest against inadequate juvenile court staffs and facilities; we “burn down the stable to get rid of the mice.” The lack of support and the distressing growth of juvenile crime have combined to make for a literal breakdown in many if not most juvenile courts. Constitutional problems were not seen while those courts functioned in an atmosphere where juvenile judges were not crushed with an avalanche of cases.
My hope is that today’s decision will not spell the end of a generously conceived program of compassionate treatment intended to mitigate the rigors and trauma of exposing youthful offenders to a traditional criminal court; each step we take turns the clock back to the pre-juvenile-court era. I cannot regard it as a manifestation of progress to transform juvenile courts into criminal courts, which is what we are well on the way to accomplishing. We can only hope the legislative response will not reflect our own by having these courts abolished.