Meghan E. Lewis


Both the federal and state governments have recognized that criminal adults and delinquent juveniles are fundamentally different. Acknowledging that juveniles are more amenable to successful rehabilitation than adults, each government has created a separate juvenile justice system to better handle these unique concerns. The federal structure for juvenile adjudication was established by the Federal Juvenile Delinquency Act ("FJDA," "the Act"), and was enacted to provide individualized rehabilitation for juvenile delinquents in an informal, less procedurally rigid setting than traditional criminal courts. The FJDA grants federal district courts considerable discretion in determining whether a juvenile should be adjudicated under the FJDA or prosecuted as an adult, as well as in balancing the broadly categorized factors enumerated in the Act. Despite the FJDA's recognition that juveniles are more suitable to rehabilitation than adults, courts seem to be moving away from a rehabilitative approach of juvenile delinquency dispositions. In United States v. MR.M, the Eighth Circuit Court of Appeals recently affirmed a punitive disposition of a teenage girl that resulted in a sentence of nearly three years of incarceration. This ruling is an example, therefore, of courts ignoring the rehabilitative purpose of the FJDA. This Note argues that the decision in United States v. MR.M marks a change toward delivering punitive juvenile justice in the Eighth Circuit, and that the informal structure of the FJDA, combined with significant judicial discretion, vague factors of consideration outlined in the statute, and a lack of sentencing guidelines has the potential to create disparate dispositions among similarly situated juveniles.

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