In re C.T.F.

A delinquency petition was filed alleging that C.T.F. (defendant) had committed a delinquent act. The juvenile hearing began just over four months after the filing of the petition. Before the hearing began, the juvenile court denied C.T.F.’s motion to dismiss the hearing on the ground that his right to a speedy trial had been violated. C.T.F. did not offer evidence to support the motion to dismiss. The juvenile court reasoned that a juvenile lacks the right to a speedy trial in a delinquency proceeding in juvenile court. The juvenile court found C.T.F. had committed the act alleged, placed him on probation, and released him into his father’s custody. C.T.F. appealed. On appeal, C.T.F. contended that juveniles had a constitutional right to a speedy trial by virtue of the Sixth Amendment to the United States Constitution and article 1, § 10 of Iowa’s constitution, which both provided the right to a speedy trial in criminal prosecutions. C.T.F. also asserted a right to a speedy trial under Iowa Rule of Criminal Procedure 27(2)(b), which provided that criminal trials were to be conducted as quickly as possible consistent with providing fair trials. A delinquent act was not the same as a public offense, and a proceeding in juvenile court was not a criminal prosecution. However, C.T.F. argued that a petition filed in juvenile court alleging a juvenile’s delinquent act was equivalent to the filing of an indictment in a criminal prosecution. Regarding a juvenile’s constitutional rights, the United States Supreme Court had ruled that if a delinquency proceeding could lead to a juvenile’s detention, the Due Process Clause of the Fourteenth Amendment mandated that states had to recognize particular fundamental rights. Subsequently, the Supreme Court applied a due-process test on a case-by-case basis to determine whether a constitutional right was applicable in the juvenile context, considering fair treatment and the nature of the proceeding. Neither the United States Supreme Court nor the Iowa Supreme Court had addressed whether a juvenile had a right to a speedy trial. The state contended that even if C.T.F. had a right to a speedy trial, C.T.F. had submitted no evidence that this right was violated.