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BROWN V CARLSON - CONFLICT OF ROLES IN THE ADMINISTRATION OF THE YOUTH CORRECTIONS ACT

NCJ Number
57040
Journal
New England Journal of Prison Law Volume: 4 Issue: 2 Dated: (SPRING 1978) Pages: 355-369
Author(s)
A M SHPIGEL
Date Published
1978
Length
15 pages
Annotation
A JUDICIAL DECISION REFLECTING CONFLICT IN THE ROLES OF THE COURTS AND THE FEDERAL BUREAU OF PRISONS WITH REGARD TO ADMINISTRATION OF THE YOUTH CORRECTIONS ACT (YCA) IS DISCUSSED.
Abstract
IN CONSOLIDATED PETITIONS FOR HABEAS CORPUS, THREE MEN SENTENCED UNDER THE YCA CLAIMED THEY HAD BEEN DENIED THE SPECIAL CLASSIFICATION AND TREATMENT MANDATED FOR YCA OFFENDERS. THE COURT GRANTED THEIR PETITION, FINDING NO EXTENUATING CIRCUMSTANCES TO JUSTIFY THE BUREAU'S FAILURE TO COMPLY WITH REQUIREMENTS THAT YCA OFFENDERS BE SEGREGATED FROM OTHER OFFENDERS AND PROVIDED SPECIAL CLASSIFICATION SERVICES IN YCA CENTERS. THE CASE POINTS UP CERTAIN CONFLICTS BETWEEN YCA AND THE BUREAU'S GENERAL AUTHORIZATION TO EXERCISE FULL CONTROL OVER THE CLASSIFICATION AND INCARCERATION OF OFFENDERS. ANALYSIS OF THE ISSUES IN THE CASE FROM THE PERSPECTIVES OF BOTH THE BUREAU AND THE REVIEWING COURT SUGGESTS HOW EACH MIGHT INTERPRET THE PURPOSE AND THE EFFECT OF THE YCA DIFFERENTLY, YET RATIONALLY. IT IS CONCLUDED THAT CONGRESS, WISHING TO EMULATE THE BRITISH BORSTAL SYSTEM, INTENDED TO CREATE THROUGH THE YCA A SPECIAL, SEPARATE SYSTEM FOR YOUNG OFFENDERS WITHIN THE FEDERAL PRISON SYSTEM, THE GOAL BEING TO REHABILITATE YOUNG OFFENDERS BEFORE THEY BECOME HABITUAL CRIMINALS. ESSENTIAL TO THE ACHIEVEMENT OF THIS GOAL IS THE ISOLATION OF YOUNG OFFENDERS FROM THE GENERAL PRISON COMMUNITY. UNLESS THE VALIDITY OF THE LAW ITSELF IS DRAWN INTO QUESTION, THE COURT HAS NO CHOICE BUT TO INTERPRET THE YCA AS IT WAS INTENDED. HOWEVER, THE BUREAU'S ROLE UNDER THE YCA IS NOT AS APPARENT AS THE COURT'S. (LKM)