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Sentencing Under the Federal Youth Corrections Act - When May a Youth Be Treated as an Adult?

NCJ Number
Loyola University Law Journal Volume: 13 Issue: 4 Dated: (Summer 1982) Pages: 849-873
C A Kelly
Date Published
25 pages
An analysis of sentencing under the Federal Youth Corrections Act (YCA) focuses on the issue of when a youth may be handled like an adult and emphasizes the Supreme Court decision in Ralston v. Robinson, in which the court addressed a circumstance not expressly provided for in the YCA.
The YCA aimed to provided a system for treatment and rehabilitation of youthful offenders. However, Congress failed to give detailed specifications regarding the act's implementation. In Ralston v. Robinson, the Supreme Court had to decide whether a youth offender sentenced to a consecutive adult term of imprisonment while serving a sentence under the YCA must receive YCA treatment for the remainder of the youth sentence. The Supreme Court held that the YCA does not require such treatment. Robinson was a 17-year-old who pleaded guilty to a charge of second degree murder. A year after his murder conviction, he was found guilty of assaulting a Federal officer while incarcerated at a Federal correctional institution. Two years later, he pleaded guilty to a charge of assaulting a Federal officer while confined in another institution. The Supreme Court preserved the broad discretion of judges to sentence YCA offenders to consecutive adult sentences. The decision ignored the YCA principle of providing treatment for youth offenders. It also raises some constitutional questions. However, the decision will be welcomed as consistent with both the trend to treat violent juvenile offenders as adults and the prevailing correctional philosophy which has rejected the rehabilitative model. The decision also recognizes the practical realities of corrections administration and the lack of separate institutions for younger offenders. However, Congress needs to decide whether to abolish the YCA or to modify it to make it more consistent with current theory. Footnotes are provided. (Author summary modified)