New York Law Review

Tag: Brito v. New York City Criminal Court

  • Brito v. New York City Criminal Court, 43 N.Y.2d 818 (1977): Defining ‘Youthful Offenders’ for Court Detention Facilities

    Brito v. New York City Criminal Court, 43 N.Y.2d 818 (1977)

    The New York City Criminal Court Act does not specify a particular age limit for defining “youthful” versus “older” offenders for the purpose of segregation in court detention facilities, leaving the determination to be made by the responsible administrative authority.

    Summary

    This case concerns whether the detention facilities at the New York City Criminal Court adequately separate youthful offenders from older, more hardened offenders, as mandated by the New York City Criminal Court Act. Petitioners, two individuals under 19, argued that the existing practice of separating those under 21 from older detainees was insufficient and that the dividing line should be 19, consistent with the youthful offender definition in the Criminal Procedure Law. The Court of Appeals held that the statute does not define specific age limits, thus the existing practice did not violate the statute. The court reversed the Appellate Division’s ruling, dismissing the petition without prejudice to further proceedings addressing who has the authority to make this determination.

    Facts

    Hector Brito and Herman Mills, both under 19, were arrested in May 1976 and detained at the New York City Criminal Court for arraignment. Due to arraignment backlogs, they spent multiple days in courthouse detention cells before being arraigned. They alleged that in these facilities, they were commingled with adults, including hardened criminals, sex offenders, and drug addicts.

    Procedural History

    Brito and Mills initiated an Article 78 proceeding in the Appellate Division, seeking mandamus and injunctive relief to enforce the segregation of youthful and adult offenders. The Appellate Division inspected the courthouse and determined that the existing practice of segregating those under 21 was invalid, holding that the dividing line should be 19 for those awaiting arraignment. The Court of Appeals granted leave to appeal.

    Issue(s)

    Whether the current practice of segregating detainees under 21 years of age from older detainees at the New York City Criminal Court violates Section 88 of the New York City Criminal Court Act, which requires the separation of youthful and less hardened offenders from older and more hardened offenders.

    Holding

    No, because Section 88 of the New York City Criminal Court Act does not define “youthful” and “older” offenders in terms of a specified age limit, thus the determination to separate youths from adults at age 21 is not prohibited by the statute.

    Court’s Reasoning

    The Court focused on the narrow issue of whether the current practice violates Section 88 of the New York City Criminal Court Act. The Court noted that while CPL 720.10 defines a youth as someone between 16 and 19, this definition applies only to Article 720 of the CPL, concerning youthful offender status after conviction. The Court also found that Section 500-c of the Correction Law, which mandates the segregation of those under 21, is inapplicable because it excludes detention facilities within New York City (except civil jails). The Court emphasized that the statute does not define ‘youthful’ and ‘older’ offenders in terms of age. The Court stated, “in every building used by the court or any part thereof for the detention of prisoners, adequate provision shall be made for the separation * * * of youthful and less hardened offenders from older and more hardened offenders of the same sex.” The Court declined to address who should properly make the determination regarding age segregation or whether the courts possess inherent power to determine how young persons should be treated within the courthouse, as these issues were not properly presented in the petition or argued on appeal. The Court reversed the Appellate Division’s judgment and dismissed the petition, emphasizing that the determination to segregate detainees at age 21 is not illegal under the statute. This decision clarifies that the administrative authority responsible for the facilities has some discretion in defining ‘youthful’ for purposes of segregation, provided it aligns with the statute’s intent.