In re Devon T.

584 A.2d 1287 (1991)

Quick Summary

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A thirteen-year-old Devon T. (defendant) tried in juvenile court for possession of heroin with intent to distribute. The defendant raised an infancy defense.

The dispute centered on whether Devon T. had the mental capacity to understand his actions were wrongful and whether his Fourth Amendment rights were violated during a school search.

The Maryland Court of Special Appeals upheld the juvenile court’s decision, affirming that sufficient evidence existed to demonstrate Devon T.’s cognitive ability to distinguish right from wrong.

Facts of the Case

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Devon T. (defendant) was a minor, specifically thirteen years and ten months old, when he was found in possession of twenty zip-lock bags containing heroin at school. The discovery of the narcotics occurred when Devon T. was compelled by a security guard to empty his pockets in the presence of the Assistant Principal at Booker T. Washington Middle School.

Following this incident, Devon T. was tried in juvenile court where he presented an infancy defense, arguing that due to his age, he presumptively lacked the criminal capacity to understand the nature of his actions.

Procedural Posture and History

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  1. Devon T. was apprehended at school with heroin and charged in juvenile court.
  2. He asserted an infancy defense during the trial.
  3. Judge Roger W. Brown of the Circuit Court for Baltimore City found Devon to be delinquent.
  4. Devon appealed the decision to the Maryland Court of Special Appeals.

I.R.A.C. Format


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  • Whether the State provided sufficient evidence to rebut Devon T.’s presumed incapacity due to infancy.
  • Whether the search that led to the drug discovery violated Devon T.’s Fourth Amendment rights.

Rule of Law

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The legal framework for assessing criminal capacity in juveniles looks at whether an individual under the age of fourteen has the cognitive ability to distinguish right from wrong at the time of committing an act. The State bears the burden of proof to rebut a juvenile’s presumed incapacity due to infancy beyond a reasonable doubt when such defense is raised.

Reasoning and Analysis

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The court examined historical legal principles surrounding the defense of infancy, which presumes children between seven and fourteen years of age lack criminal capacity unless proven otherwise. The court also reviewed the evolution of juvenile court proceedings, noting that due process protections afforded to adults have increasingly been applied to juveniles.

This shift necessitates that juveniles be granted defenses based on mental incapacity, including infancy. The court clarified that a cognitive inability to distinguish right from wrong is central to asserting an infancy defense.

In this case, once Devon T. raised the issue of incapacity due to his age, it became the State’s responsibility to provide evidence that he possessed the mental capacity to know his actions were wrong. Historical common law and recent jurisprudence both underscored this cognitive standard as pivotal in determining criminal responsibility.


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The court ultimately concluded that Devon T.’s conviction for delinquency should stand, as the State had met its burden of proving that he possessed the necessary criminal capacity despite his young age.

Key Takeaways

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  1. The defense of infancy presumes that juveniles between seven and fourteen years old are incapable of criminal intent unless proven otherwise.
  2. The State must prove beyond a reasonable doubt that a juvenile has the cognitive capacity to understand right from wrong if they are to be held criminally responsible.
  3.  Juvenile delinquency proceedings require due process protections similar to those in adult criminal trials, including defenses based on mental incapacity.

Relevant FAQs of this case

What is the standard for evaluating criminal capacity in juveniles, and how does it differ from adults?

In evaluating criminal capacity, the law recognizes a developmental difference between juveniles and adults by presuming that children within certain age brackets, particularly between seven and fourteen years, may lack the mental maturity to form criminal intent. Unlike adults, where competence to stand trial is almost always presumed, children are given the benefit of doubt based on age-related cognitive development. To counter this presumption, the prosecution must provide clear evidence that the juvenile possessed sufficient mental capacity to understand the wrongfulness of their conduct.

  • For example: A ten-year-old child found vandalizing property may not be presumed to have the same understanding of their actions as an adult would; thus, the court would require substantial evidence to show that the child knew this action was wrong and was fully aware of its consequences.

How does the State meet its burden of proof when overcoming an infancy defense?

To surmount an infancy defense, the State must demonstrate beyond a reasonable doubt that despite the juvenile’s age, they had both the mental capacity and maturity to distinguish between right and wrong at the time of committing the act in question. This typically involves presenting psychological evaluations, witness testimony about the juvenile’s behavior, or other evidence that reflects a developed moral and cognitive understanding.

  • For example: If a twelve-year-old is accused of a crime, presenting school records and testimonies showing advanced moral reasoning or previous acknowledgements of wrongdoing by the juvenile might be used to rebut the infancy defense.

What constitutional protections are afforded to juveniles during delinquency proceedings?

Juveniles are granted many of the same constitutional protections during delinquency proceedings as adults during criminal trials. This includes the right to due process, protection against self-incrimination, and potentially challenging searches and seizures under the Fourth Amendment. However, there might be certain variations such as more lenient evidentiary standards or modified procedures reflecting a focus on rehabilitation over punishment.

  • For example: A student’s locker being searched at school for drugs may invoke Fourth Amendment scrutiny, but courts often apply a lower standard of ‘reasonable suspicion’ rather than probable cause due to the context of safety within schools.


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