Shawn M. v. State

OPINION

The juvenile court found that appellant Shawn M., a minor, committed battery, and the court adjudged him a delinquent child. However, at the adjudicatory hearing, the juvenile court refused to hear Shawn’s counsel in summation. On appeal, Shawn contends that he had a constitutional right to present closing argument in the juvenile proceeding. We agree.

The United States Supreme Court’s seminal case on due process requirements in juvenile proceedings supports Shawn’s position. In re Gault, 387 U.S. 1 (1967). The court observed that, regarding the right to counsel, no material difference…