Newswise — A Florida appeals court's decision Wednesday (Dec. 10, 2003) to order a new trial in the case of Lionel Tate--who, at age 14, was tried and convicted as an adult in the murder of a six-year-old playmate in 2001--is consistent with findings by a research network of nationally prominent researchers studying juvenile justice issues.
In ruling that Tate's first-degree murder conviction and life sentence without parole should be reversed because the teen's competency should have been tested prior to his trial, judges from the Fourth District Court of Appeal stated:
"[I]n light of Tate's age, the facts developed pre-trial and post-trial, and his lack of previous exposure to the judicial system, a competency hearing should have been held, particularly given the complexity of the legal proceedings and the fact that he was denied this protection afforded children fourteen and older under section 985.226(2), Florida Statutes, which provides for a waiver hearing to determine whether the child should be tried as an adult."
The ruling is consistent with findings released this year by the John D. and Catherine T. MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice, the first systematic, large-scale study to examine whether immaturity--rather than mental illness or mental retardation--can impair defendants' capacities to participate in their trials, according to Temple University adolescent psychologist Laurence Steinberg, who directs the network.
In the study, researchers from the MacArthur Network found that a significant proportion of children age 15 and younger who are charged with a crime don't possess the intellectual and emotional maturity to understand the judicial process and contribute effectively to their own defense.
"Our findings indicate that significant numbers of juveniles who are 15 and younger are probably not competent to stand trial as adults," says Steinberg, the Distinguished University Professor of Psychology at Temple. "It is perfectly consistent with our study to raise questions about whether Lionel Tate's competence should have been evaluated before he was tried as an adult."
In the four-site study of 1,400 males and females ages 11-24, children ages 11-13 were more than three times as likely as young adults to be found "seriously impaired" in evaluations of their abilities to understand the trial process and to contribute to their own defense.
Young people in the 14-15 age range were twice as likely as young adults to be found "seriously impaired," while the performance of adolescents 16 and older did not differ from that of young adults, according to the researchers.
Additionally, researchers found that young people with below-average intelligence--an IQ under 85--were at the highest risk of lacking abilities for competence to stand trial. Many young people in the juvenile justice system are of below-average intelligence, the study noted.
Steinberg notes that the U.S. Supreme Court has ruled that, in order to have a fair trial, defendants must understand the charges against them, have some rudimentary understanding of the court proceeding, be able to understand and answer questions posed to them by their attorney, and be able to make basic decisions about their trial, such as weighing the consequences or accepting or turning down a plea agreement.
"In view of our findings," he says, "states should re-examine the age at which it is permissible to try juveniles as adults or, at the very least, require that a competence evaluation be performed before transferring a young adolescent into the adult system. The court's decision in the Tate case is eminently sensible."
Directed by Thomas Grisso, a clinical psychologist and Professor of Psychiatry at the University of Massachusetts Medical School, the study involved individuals already detained in juvenile detention centers or jails, as well as those who had never been detained, at research sites in Philadelphia, Northern and Eastern Virginia, Los Angeles, and Northern Florida.
The researchers utilized a standardized battery of tests to assess participants' knowledge and abilities relevant for competence to stand trial, their legal decision-making in a number of hypothetical situations (such as whether to confess a crime to police, share information with an attorney, or accept a plea agreement), and measures of characteristics such as intelligence, symptoms of mental health problems and prior experience in the justice system. The study found that juveniles age 15 and younger differed from young adults in their legal decision-making. They were less likely to recognize risks in making certain decisions and less likely to ponder the long-term consequences of their choices. A full report of the study was published in August in the journal Law and Human Behavior.
"These are kids," says Grisso, "who are often asked to accept or reject plea bargains that have very long-term consequences, and no one else is allowed to make the decision for them. What we found wouldn't surprise any parent of a 13- or 14-year-old. At that age, they are frequently not as equipped as the average adult to grasp the consequences of legal decisions that will seal their fate for the rest of their lives."
Current law does not include these developmental factors as relevant when considering a defendant's competence to stand trial, he notes. "Our findings suggest that states need to take a closer look at current policies and practices that don't recognize immaturity as a possible reason for incompetence to stand trial," Grisso noted.
The MacArthur Juvenile Adjudicative Competence Study is one of a number of juvenile justice studies being conducted by the MacArthur Network. The national, multi-disciplinary group, now in its sixth year, brings together leading scientists, researchers and practitioners to conduct ground-breaking, comprehensive research examining complex issues concerning adolescent development, juvenile crime and delinquency, and the treatment of young people within the juvenile and criminal justice systems.
"Courts around the country are increasingly asked to consider the competence of young juveniles charged with serious crimes," notes Steinberg. "The decision in the Tate case will likely put this issue on the national radar screen."
In addition to Steinberg and Grisso, researchers on the Juvenile Adjudicative Competence Study include: Jennifer Woolard, Georgetown University; Elizabeth Cauffman, University of Pittsburgh; Elizabeth Scott, University of Virginia School of Law; Sandra Graham, University of California-Los Angeles; Fran Lexcen, University of Massachusetts Medical School; N. Dickon Reppucci, University of Virginia; and Robert Schwartz of the Juvenile Law Center in Philadelphia.
For information on the MacArthur Foundation Research Network on Adolescent Development and Juvenile Justice or to view the study and its summary, go to http://www.adjj.org.
An online version of this release is available through the Office of News and Media Relations at: http://www.temple.edu/news_media/bb0312_458.html.
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