In re Winship, 397 U.S. 358 (U.S. 1970)
In re Winship is the Supreme Court's foundational decision constitutionalizing the burden of proof in criminal adjudication. While the presumption of innocence and the beyond-a-reasonable-doubt standard had long been entrenched in Anglo–American tradition, Winship transformed that tradition into a constitutional requirement under the Due Process Clause of the Fourteenth Amendment.
Does the Due Process Clause of the Fourteenth Amendment require the State to prove beyond a reasonable doubt every fact necessary to establish juvenile delinquency when the alleged conduct would be a crime if committed by an adult?
The Due Process Clause protects the accused against conviction except upon proof beyond a reasonable doubt of every fact necessary to constitute the offense charged. This constitutional standard applies not only in adult criminal prosecutions but also in juvenile delinquency proceedings when the conduct alleged would be a crime if committed by an adult.
Yes. The Constitution requires proof beyond a reasonable doubt of every element in a juvenile delinquency adjudication based on criminal conduct; New York's preponderance-of-the-evidence standard violated due process.
Winship constitutionalized the beyond-a-reasonable-doubt requirement and extended it to juvenile delinquency cases involving criminal conduct. For law students, Winship is the starting point for understanding allocation of the burden of proof and the State's obligation to establish every element of an offense. The case underpins later decisions on burden shifting and elements, including Mullaney v. Wilbur (requiring the State to prove facts that increase culpability), Patterson v. New York (permitting the State to place the burden of certain affirmative defenses on the defendant), and cases policing jury instructions about reasonable doubt. It also complements In re Gault, confirming that juvenile courts must observe core procedural safeguards when liberty is at stake.