Swisher v. Brady

The Maryland Appellate Court implemented a new rule (the juvenile-court rule) concerning the use of masters in juvenile-court proceedings. Masters were officials appointed by juvenile-court judges and were essential to Maryland’s juvenile-court caseload management. Masters presided over hearings and proposed findings of fact, conclusions of law, and dispositions to juvenile-court judges, who could adopt or reject the masters’ proposals. State attorneys who appeared in a prosecutorial role (state’s attorneys) (defendants) could file exceptions, which were similar to appeals, to a master’s proposal, but the juvenile-court judge did not review the matter de novo. Instead, the judge considered the record that had been established before the master, supplemented by any evidence agreed upon by the juvenile and the state’s attorney. Juveniles who were parties to proceedings in which the state’s attorney filed exceptions to a master’s proposal (the juveniles) (plaintiffs) formed a class and sued the state’s attorneys in federal district court, seeking declaratory relief and an injunction to bar the state’s attorneys from filing exceptions to the masters’ proposals. The juveniles argued that the hearing before the master placed them in jeopardy and the juvenile-court judge’s review impermissibly put them in jeopardy a second time, violating the Double Jeopardy Clause (DJC). The federal district court found for the juveniles and enjoined the state’s attorneys from filing exceptions to certain proposals issued by masters. The United States Supreme Court reviewed the matter.