It also concluded that the New York statute provided adequate procedural safeguards to justify pretrial detention. The Schall decision may result in a future increase in juvenile pretrial detention. While detention pending trial causes a poignant detrimental effect on the juvenile, it often may be justified by practical and realistic necessities. The judge must strike a balance between the child's right to pretrial freedom and the protection of society, the juvenile, and trial administration. Further, the Supreme Court should not extend its holding to adult criminal defendants: the Court has recognized an express Federal statutory right to bail for adults, whereas none exists for juveniles. Further, the Court's heavy reliance on the parens patriae doctrine in the Schall decision is inapplicable to adult defendants. 233 footnotes.