88 N.Y.2d 593 (1996)
Procedural due process is satisfied when a Family Court determines, after an inquiry and opportunity for the juvenile to respond, that there is a legitimate basis for concluding that a juvenile violated a condition of an adjournment in contemplation of dismissal (ACD), and states the reasons on the record.
Summary
This case addresses the due process requirements for vacating an adjournment in contemplation of dismissal (ACD) in juvenile delinquency proceedings. The Court of Appeals held that a full evidentiary hearing with confrontation of witnesses is not always required. Instead, due process is satisfied if the Family Court conducts an inquiry, allows the juvenile to respond, and determines there is a legitimate basis for concluding a violation occurred. This determination balances the juvenile’s liberty interest against the State’s interest in swift resolution of juvenile cases. The dissent argued for stricter procedural safeguards, akin to parole revocation hearings.
Facts
A 13-year-old, Edwin L., was charged with acts that would constitute crimes if committed by an adult. Based on Edwin’s admissions, the Family Court issued fact-finding orders. At the dispositional hearing, with the presentment agency’s agreement, Edwin sought an ACD, which the court granted. The ACD order required Edwin to attend school, reside at a residential facility unless adopted, and avoid further contact with the court. A violation petition was later filed, alleging Edwin had failed to comply with the residence and “no further contact with court” conditions. This petition stated he had been AWOL from the facility and arrested.
Procedural History
The presentment agency filed a violation petition alleging violations of the ACD. The Family Court held a hearing where a caseworker testified about Edwin’s AWOL status, arrests, and fights with other residents, largely based on hearsay. Edwin’s motion to strike the testimony as hearsay was denied, and the court vacated the ACD order. Edwin waived his right to a dispositional hearing and was placed with the Division for Youth. The Appellate Division affirmed, and Edwin appealed to the Court of Appeals on constitutional grounds.
Issue(s)
Whether procedural due process requires Family Court to conduct a hearing, at which hearsay evidence may be considered only after a finding of good cause, before finding that a juvenile has violated the conditions of an adjournment in contemplation of dismissal (ACD)?
Holding
No, because neither the Family Court Act nor the requirements of procedural due process impose such restrictions upon the discretion of the Family Court to vacate an ACD order, provided the court conducts an inquiry, allows the juvenile to respond, and finds a legitimate basis for concluding a violation occurred.
Court’s Reasoning
The Court applied the balancing test from Mathews v. Eldridge, weighing the private interest at stake (the juvenile’s liberty), the risk of erroneous deprivation of that interest, and the state’s interest. The Court distinguished an ACD from dispositional orders like probation, noting that an ACD is granted before a delinquency adjudication and offers a chance to clear the record. The Court reasoned that vacating an ACD merely brings the juvenile back to the pre-disposition stage, entitling them to a dispositional hearing. It analogized the situation to People v. Outley, where a legitimate basis for an arrest justified modifying a plea agreement. The Court held that due process requires an inquiry where the juvenile can respond, and the court states its reasons for finding a violation. While the form of the inquiry varies, a more detailed inquiry is needed if the juvenile denies the violation. The Court emphasized the State’s interest in swiftly addressing juvenile delinquency. The dissent argued that a post-fact-finding ACD release is functionally equivalent to parole or probation, requiring the procedural protections outlined in Morrissey v. Brewer, including the right to confront and cross-examine witnesses unless good cause is shown to dispense with confrontation.