The Case for Alternatives to Detention

The Case for Alternatives to Detention

By Edward Pabon

In no other area of human services has the contrast between aspirations and reality been so disparate as in the field of juvenile justice. For at least 100 years we have espoused ideals of rehabilitation rather than punishment, but seldom have we been able to implement suc- cessfully programs that were in fact rehabili- tative. This failure has been of particular concern in juvenile courts and correctional programs because of the high hopes that existed for so long. At the same time reports about increases in crime among juveniles have resulted in mounting pressures on law enforcement, judicial and correctional per- sonnel to “do something” about adolescent law-breakers. What the public wants done, however, is not clear, for demands are con- tradictory. Because the public demand for punishment has been stronger than that for rehabilitation, and because juvenile courts have punished while intending to reform, official responses to delinquency have often resulted in stigmatization, locking out, puni- tive coercion and education in crime. One of the most visible manifestations of extant patterns is institutionalization of a juvenile in secure detention, and it is a major priority for reform.

The decision to remove a youngster from his current surroundings and place him in detention is a complex, sometimes informal

and hurried decision made by a police officer or a judge often with limited information. But taking a youngster into custody is not a routine procedure; it is, rather, a policy-making process. The decision may have long-lasting consequences for the juvenile involved and for the juvenile justice system to which he has been introduced. The detention period is con- sidered one of the most critical experiences during the court process and how juveniles are handled at this point may affect their later prospects for change. The fact that detention can be a period of uncertainty and crisis for the juvenile and a period which demands careful provisions requires that the policies surrounding the administration of detention be closely examined.

Use of Secure Detention Many observers have commented on the

fact that the modern American strategy for correcting juveniles tends to rely on an emergent policy. The policy is: offer more juveniles detentionljailing than any other correctional response. In the United States, nearly 1 mil- lion children are admitted to detention facilities yearly. On any given day, about 12,000 youngsters are being held in more than 300 detention centers in the nation.’ In New York state alone, 12,740 detention admissions were

August I983 Juvenile & Family Court Journal 37

Edward Pabon

recorded in 1979; and 8,551 of these were admissions to secure detention.2

There is a general consistency among various definitions of detention. Most definitions agree on three common elements: juvenile detention consists of (1) temporary care, (2) while awaiting court adjudication, placement or transfer to another jurisdiction, (3) in a physically restricting setting. However, spe- cific definitions and conceptions of detention vary. For instance, New York state defines detention exactly as others except that, in- stead of stating that detention is temporary care in a physically restricting facility, it uses the terms, “detention shall mean temporary care away from their homes of children held . . . pending court or return to another jurisdiction.”3 This definition allows the use of “non-secure” detention which is temporary care of children held for court in “a facility characterized by the absence of physically restricting construction, hardware and procedures.”

Other states make provisions for detention in settings that are not physically restricting. Pennsylvania, California and Utah also provide for non-secure detention.4 Illinois, Ohio and Missouri allow delinquency and status offenders to be placed in foster homes or shelters during the court process.5 Florida has established a community detention program which combines intensive supervision during the court process with non-secure homes if needed.6 These alternative detention programs have probably diverted a large number of juveniles from physically restricting facilities where complete security was not necessary to insure court appearance or to protect community safety. Yet, we continue to use secure detention at an increasing level.

Recent data suggest that a greater empha- sis on due process inside the courtroom and a verbal commitment to diversion and community-based programs have not halted the reliance on detention lockups. According to a recent report released by the National Center for the Assessment of Alternatives to Juvenile Justice Processing, approximately 520,000 juveniles were admitted annually to detention centers during the mid- 1970s.’ In addition, approximately 120,000 juveniles were de-

tained annually in adult jail during the same time period. In 1973 alone, according to one survey, an estimated 100,000 youngsters spent at least one day in an adult jail and nearly 500,000 other youths were admitted to local detention facilities.8 These figures represent an increase of 50 percent over the 1965 statistics and are certainly higher than the population at risk of detention.

On a local level, a recent study of detention practices in New York state indicated that, although secure detention admission totals have declined during the past five years, a notable increase in non-secure detention util- ization shows more of a change in usage patterns than a significant decline in overall detention admissions.9 Since 1975, there has been a nearly 30 percent reduction in secure detention admissions in New York state. Much of this is attributable to the removal of status offenders from secure detention. An accurate assessment of the decrease in the use of secure detention must, therefore, include a consideration of non-secure usage.

It is estimated that there were 1,600 admissions in 1975 to non-secure facilities; by 1979, this figure had risen to 4,189 admissions. In 1975, only 12 percent of the total number of detention admissions were to non-secure facilities; whereas in 1979, one-third of the admissions were to non-secure detention. This change was made possible by the dramatic increase in the availability of non- secure spaces. For example, in 1977, there were 280 certified non-secure beds; in 1979, there were 470 beds. The combined totals for the years 1975 and 1979 show a decrease of about 727 admissions, representing only a 5 percent decrease in the use of the detention system in general. Thus, the 30 percent decrease in the use of secure detention is largely compensated for by the increased use of non-secure facilities. While the use of non- secure detention is clearly an important reform, it must not be allowed to disguise the fact that large numbers of juveniles are still being brought into the residential detention system.

An Over-Reliance Correctional Response According to Judge Carrel1 McGraw, who

38 Juvenile & Family Court Journal/ August 1983

The Case For Alternatives to Detention

released the survey’s findings, “children may be legally placed in jail only if they are over the age of 14 years and are charged with the commission of a violent felony or are males 16 years of age and older who are awaiting transfer to a correctional institution.

Of the 377 juveniles who were jailed from Jan- uary 1 to June 30, 334 appear to have been locked up illegally. Only 43 of the incarcerations appeared to comply with the law, according to the survey. Thirty of those 43 were jailed for committing violent felonies and 17 were awaiting transfer.

Of the 334 illegal incarcerations, 160 of the youths were jailed for misdemeanors; seven for violations of probation; 51 for status offenses; 97 for non-violent felonies; and 15 for unspeci- fied reasons.lo

This demonstrated preference for short- term lockups has never been set forth in any written publication that I have been able to locate. It cannot be found in philosophical statements of “progressive” reforms, legislative preambles to 20th century juvenile court statutes, judicial opinions, court administrative guidelines, local police manuals or any other type of document. But this pervasive practice of using detention as “short-term lockups” or as an unofficial correctional disposition exist anyway.

While there is general agreement about the types of juveniles who should be detained, i.e., those who will run away before court or placement and those who will commit another crime, it is obvious that the criteria for detention are open to a variety of interpreta- tions and encompass a wide area of discre- tion. They require what are predictive and often subjective judgments. In New York state, both the Family Court Act criteria for detention admissions and the administrative regulations of the state juvenile correctional agency are vague and do not offer precise guidelines. The statute’s phrase “substantial probability” is open to a wide range of inter- pretations.” The same vagueness is associated with interpretation of the second point, the ‘‘serious risk” of committing a crime. In fact, a recent court decision, United States ex rel. Martin v. Strasburg, ruled unconstitu- tional the provision of the New York State

Family Court Act that allowed juveniles to be detained pending trial based upon judicial predictions that they will commit crimes if released. The court held that to detain ajuvenile, prior to a hearing, on the basis of a prediction of likelihood to commit a crime violates the juvenile’s rights to a presumption of innocence and due process. It reasoned that the statute in question gave the judge a “license to act arbitrarily and capriciously in a prediction of the likelihood of future criminal conduct which cannot result from a reasoned determination, that pretrial detention without a prior adjudication of probable cause is, itself, a per se violation of due process, and (3) in addition, constitutes punishment that is constitutionally impermissible under the due process clause.”l2

Furthermore, one might anticipate that the alleged present offense would predict the decision-making outcome. Yet, a recent study of detention admissions in New York state indicated that the majority of secure detention admissions are not charged with serious offenses.13 In 1979, less than 25 percent of the secure detention admissions were charged with serious offenses.

Moreover, the question of racism arises in the figures on ethnicity of detention admissions. For instance, minority admissions accounted for more than 70 percent of the secure detention totals in the above study. Minority representation in the detention population was substantially greater than in the general population. 14

In a cohort study carried out in Racine, Wis., it was found that “minorities make up a disproportionate number of those referred to the juvenile court because they have more police contacts, more contacts for more serious categories of behavior, and a disproportionate number are referred beyond what would be expected considering the categories of behavior into which their reasons for police contact fall. . . .”I5 At the same time, this study found that “the idea of Blacks and Chi- canos as the focal point of the delinquency and crime problem is not only distorted by the failure to consider the spatial distribution of minorities (their ecological status) but is to a considerable extent a fiction based on con-

August 19831 Juvenile & Family Court Journal 39

Edward Pabon

fusing contextually-derived behavior and the characteristics of groups. . . . ” I6

In accordance with most juvenile justice standards, the category of youth unnecessarily admitted to secure detention includes all those for whom a less restrictive form of restraint would suffice. The Juvenile Justice and Delinquency Prevention Act of 1974 calls for the use of the “least restrictive means” possible, consistent with public safety, for the detention of juveniles. Yet, secure detention statistics in New York state are evidence of the failure to comply with this principle. In 1979, less than 10 percent of the securely- detained youth population were given secure placement upon adjudication; more than two-thirds of all detention admissions were detained in secure facilities.

Today we usually refer to detained youngsters as being “under lock and key.” From an historical perspective, detention emerged as a juvenile functional equivalent for local jails. That is why many of them have bars on the windows and secure architecture built into their designs. Living conditions may be less harsh than residence in a local jail, but that fact does not change its functioning as a “community-based social control” facility. Furthermore, if we treat a juvenile jailing as functionally equivalent to a detention, then it is possible to conceptualize this experience as also functioning as a non-formal, but actual, dispositional tool. For example, more than 50 percent of the total admissions to secure detention in 1979 in New York state were released in three days or less, and approximately 45 percent were released to their homes. 18 This over-reliance on detention suggest its use as a disposition device by the juvenile justice system.

The juvenile court’s well-documented use of detention after arrest as a substitute for formal adjudication represents a troublesome social control issue. Perhaps the notion of using short-term lockups for this kind of additional social function is at odds with our self-proclaimed ideal image of providing “prevention” and “treatment.” Historically, since the turn of the century, we have not had a legitimate, short-term custodial disposition separate and apart from a lengthy stay at a

training school. Officials have apparently adapted to this system deficiency by creating a short-term lockup as the dominant correctional response to juvenile misdeeds - without explicitly calling it a type of disposition. The pervasive dominance of this correctional response indicates that it serves multiple social control functions for communities throughout the nation. Nationwide, detention is about seven times as frequent as post-adjudication commitment to secure facilities.19 As a result, this might explain why there has been a scarcity of service programs developed as alternatives to detention.

Danger to the Community or to the Youngster

The juvenile justice literature of the past 10 years contains many private and public organization and commission reports criticizing detention practices throughout the nation.

The detention ofjuveniles . . . represents m e of the most serious problems in the administration of juvenile justice. . . . (it is) caused or compounded by profound defects in the system ofjuvenile justice itself in the inadequacy of the information and the decision making process that leads to detention; in the delays between arrest and ultimate dispositions; and in the lack of visibility and accountability that pervades the process.20 Yet, detention prior to adjudication is a

part of the juvenile justice system which has received relatively little research attention. The decision to detain usually takes only a few minutes before a judge. Little information as to the necessity of detention is ordinar- ily available, limited mostly to what the youngster, arresting officer or complainant and probation officer can furnish. The object of pretrial detention in the adult court is to assure the alleged offender’s presence at trial; but in the case of juveniles, the purpose is much broader because of the court’s power to act in the “best interest of the child” and to provide services that the judge or staff deems necessary or desirable.

For many youngsters detention is their first institutional experience with juvenile justice. The majority of detained youngsters are not subsequently committed to the state correc-



tional system, but in detention they acquire an inkling of what to expect if they continue to get into trouble. The sociopsychological effects of detention are not clear but may have a significant impact on a youth’s self-image, confidence or feeling of alienation. On the other hand it is possible that many juveniles are able to neutralize the effects of this experience in various ways. Equally or more important, however, detention signifies to others who must make decisions about him, that inithe judgment of the court he must be separated from society while awaiting adjudication of his offense. Furthermore, the decision to place a juvenile in a secure detention facility as compared to a detention foster home or shelter care facility offers a basis for characterization which may profoundly influence subsequent decision-makers responsible for his care. The findings of a recent study indicated that 47 percent of the youths detained in custodial settings were subsequently placed in secure programs compared to 18 percent of the youth detained in treatment facilities and 9 percent in shelter care units.21 This might not be particularly surprising except for the fact that the study data also indicated: (1) that age (younger youths) and proximity of a detention facility were the var- iables most strongly related to the decision to detain in the first place; and (2) that decisions to detain in custodial, treatment or shelter care were most strongly related to the availability of alternatives to secure detention and to the youths’ runaway histories. It raises the spectre of a “system” so inconsistent that it differentially handles a group of youths for the most part more similar than not. More- over, the initial differences in where a youth is detained generate more serious dispositions later on at the hands of the same system.

The argument that many youngsters are unnecessarily detained and that they could be released without increasing the threat to the safety of the community or to the operation of the court process is more directly bolstered by a recent study.22 The author chose two counties in which detention practices were generally in accord with the 1976 standards of the National Advisory Committee on Stan- dards for the Administration of Juvenile Jus-

tice - Gloucester County, N.J., and Taos County, N.M. - and two counties in which detention practices were not - Salt Lake County, Utah, and Lenewee County, Mich. Gloucester and Salt Lake are primarily urban counties, and Taos and Lenewee are rural. In the counties studied, the author found not only the predictable variations in detention practices, but also the lack of relation between detention practices and the character of the court referral population. For instance, when he applied the national standards to the court records of Gloucester and Salt Lake counties, Gloucester County showed up with a more serious offender population. According to the standards, 17 percent of the court referrals in Gloucester could have been detained while only 8.3 percent of the court referrals in Salt Lake should have been. In practice, however, only 8 percent of the Gloucester referrals were detained but a full 14. I percent of the referrals in Salt Lake were detained. This sort of dis- crepancy was even more dramatic in the case of the rural counties. Despite the fact that the application of the national criteria indicated that about the same percentage of the court referrals should have been detained in the two counties, Taos County detained no youngsters for more than 12 hours between arrest and final disposition of the case while Lene- wee County detained 30 percent.

What the study goes on to show is that Gloucester and Taos counties were able to release the arrested youth without any additional threat to the community’s safety or the court process. Among these four counties,- there were no significant differences in the rates at which youngsters failed to appear for subsequent judicial proceedings. Likewise, the rates at which youngsters were rearrested in the period between their initial contact with the courts and the final disposition of their cases was roughly similar, except for Salt Lake County -with its higher rate of detention - where 21.5 percent of the youngsters were rearrested before the final disposition of their first referral in contrast to 12.5 percent in Gloucester County.

The Case for Alternatives No matter how well-intentioned its admin-

August 1983 Juvenile & Family Court Journal 4 1

Edward Pabon

istration, secure detention is imprisonment. It is handcuffs from court to facility and a strip- search upon admission. It is lack of freedom, choice and spontaneity. It is separation from familiar surroundings, parents, siblings and friends. It is stale air and limited access to the outdoors, regulations, regimentation and routine. It is enforced passivity and boredom, the lack of variety in places, faces and activities. Detention is temporariness, the limbo of not knowing, of living with anxiety and uncertainty about what will happen next, of being outside one’s world,

Secure detention is incarceration within a system traditionally hidden from public view and legislative scrutiny. While the majority of detained youth in the New York state secure detention system in 1979 were 14- to 15-years old, some were as young as 1 0 . 2 3 Three out of every four were accused of a serious crime. Fifty percent were released from detention in three days or less. After adjudication, less than 9 percent were sent to any type of secure detention. In New York state costs for main- taining youth in secure detention generally range from $90 to $120 per day for each youth, and can reach $180 per day as in New York City.

Many observers of juvenile detention practices in this country are often befuddled by the tendency to introduce factors beyond protecting the public safety and court process into detention decisions. A thorough literature search by Pappenfort and Young revealed that detention is often used “for punishment, for the administrative convenience of the court, and for lack of available social services for youths and their families.’’24 Con- sequently, two identical youngsters arrested on identical charges, but in different jurisdictions may face vastly different experiences. One youth may be released to the custody of his parents. The other youth, however, may be detained in ajuvenile detention center for an indefinite period, struggling to survive in an environment which is at best uncertain.

Yet, there are many examples of successful alternatives to secure detention for juveniles.

Home detention programs permit youths to reside with their parents while meeting

with probation officer aides at least daily. Some jurisdictions emphasize the supervision and surveillance aspects of this approach, while others stress the service components.

Attention homes are group homes usually housing between five and 12 juveniles plus one set of live-in house parents. Frequently the home is a converted single-family dwell- ing in a residential neighborhood so that the juveniles can continue attending their schools. Social service workers are often available to the juveniles and to the adults providing care.

Runaway programs are also group resi- dences, but they differ in certain respects from each other and from the attention homes. Admission is not limited to juveniles referred from detention intake, and the program emphasizes intensive counseling to resolve immediate crises, followed by referrals for longer term help if needed. Youths usually only stay a short time since the primary goal is to help them return to their natural parents.

Private residential foster homes can be quite diffferent from one another. For example, one program might pay single women aged 20-30 to take one girl at a time into their homes for 24-hour care and supervision while agency staff develop full treatment plans. In contrast, another agency might set a network of foster homes (two beds each), group homes (five beds each) and a receiving unit group home (four beds). In addition to the foster parents and group home parents, small numbers of professional staff provide counseling and advocacy services.

In their careful analysis of home detention, attention homes, runaway programs and private residential homes, Pappenfort and Young found that upward of 90 percent of juveniles in programs providing alternatives to secure detention neither committed new offenses nor ran away.25 For the 14 programs studied the failure rate - i.e., proportion of youths allegedly committing new offenses or running away while in the program - ranged from 2.4 percent to 12.8 percent. The various program formats appear to be roughly equal in their ability to keep their charges out of trouble and available to the court. The higher rates of failures appear to be caused by fac-

42 Juvenile & Family Court Journal] August 1983


tors outside the control of program em- ployees, such as excessive lengths of stay caused by slow court processing.

Interestingly, the range of alternative to detention programs appears to be most scarce in metropolitan urban areas, i.e., New York City, where there are abundant resources for the development of such programs. This is especially the case in terms of implementing “tracking” or “big brother/ sister” types of non-residential alternatives. For instance, there are numerous small local or indigenous social, welfare, fraternal and community organizations in every neighborhood in an urban city which could be utilized to provide home detention services to youngsters within their area. Two or three such organizations could be identified in a particular community planning board or neighborhood and con- tracted on a fee or voluntary basis for delivery of services to youngsters referred by the local detention authorities or court system. Where necessary, linkages could be established with major local agencies in each community planning board district, i.e., a multiservice center, to provide intensive social services to youngsters and their families, and to serve as supports to the indigenous organizations.

Neighborhoods and communities that may foster criminal character in youths also have many natural human resources that, if prop- erly tapped, can be effective in addressing the community’s most complex problems. A community can be a viable organism. When it suffers acute breakdown, it moves to fight off threats to its existence. Over the past decade, programs and activities in several cities throughout the country have been studied in which community members themselves are using their own resources to deal with the problems of youth.26 The apparent effective- ness of these neighborhood projects is impres- siLe. Youths who were once anathema to community stability have reversed roles and are now acting as protectors of their own neighborhoods. The successes appear to be based on principles of youth development associated with a strong sense of “family,” binding together adult supervisors and the youths to be changed.

In these programs a structure of primary relations among members support the possibility of cooperation and authentic mutual influence, as individual and community development proceed together. The importance of primary bonding in any person-changing process must be stressed. Socialization and development are influenced by contact with other socialized beings. In this, conformity is never total, and individuals observe some norms and ignore others. But the desire to be with people in gratifying ways leads the individual to compromise, and the gratification from finding needs met through encounters with others and the development of emo- tional and practical interdependence increase the individual’s willingness to modify the self in group-approved directions.

The chance that anyone will genuinely sub- ordinate learned adaptations to the influence of a new group and new norms depends on the degree to which the new group resembles or is in fact composed of already familiar people with whom the individual can readily find things in common. It seems probable that those with whom he may have associated all along - people from his own neighborhood, people of the same social, cultural and eco- nomic circumstances - could gain entrance to his deeper personal feelings and strivings more readily than professional helpers drawn from other social categories, educational lev- els or cultural orientations. The already- familiar neighborhood people are also more readily accepted in psychodramas of self- renovations than similar but unchosen associates.

Moreover, inner-city neighborhoods, where social and cultural identities are widely shared, have the potential for acting as true communities; that is, they are not mere aggre- gates of statistics of social problems and social disorganizations. There is the strong possibility that the residents will come together in conscious awareness of shared problems and relationships, forming communities of interest. They recognize the commonality of their life chances and adaptive styles and accept the responsibility to advance the common good. The involvement of local social,


Edward Pabon

welfare, fraternal, religious and community groups and their residents in the development of non-residential and “family-style’’ alternatives to detention is an exceptional opportunity.

Epilogue There will continue to be a steady, if irregu-

lar, need for secure detention for some juveniles charged with serious offenses. But the present indiscriminate use of detention after arrest as a substitute for formal adjudication represents a troublesome, and unjustified, social control device. Many private and public organization and commission reports have criticized detention practices throughout the nation. They have all indicated their bewil- derment over the tendency to introduce factors beyond protecting the public safety and court process. At the same time, studies have demonstrated that many youngsters are unnecessarily detained and that they could be released without increasing the threat to the safety of the community or the operation of the court process. Unfortunately, the wide- spread use of detention can be explained by the realization that we have not had a legitimate, short-term custodial dispositional option separate and apart from a lengthy stay at a training school within our sentencing packages. Detention serves this purpose; it is an informal correctional response to juvenile misdeeds - without explicitly calling it a type of disposition.

There must be flexibility in handling juvenile offenders, so that the number ofjuveniles in secure settings is reduced. Flexibility must be evident not only in legislative and administrative criteria governing selection of youths for detention and in the decision as to whether youths are to be placed in secure detention or an alternative program, but there must be available a wide variety of alternative programs, including non-residential ones. The abundant “natural” resources of our communities must be involved in the development and implementation of these programs.

The pervasive dominance of secure detention as a correctional dispositional response and a recognition of the profound impact of the detention decision on future decision-

makers and dispositions underlies the importance of this correctional tool, and argues for the development of alternatives to an emergent policy that offers more juvenile jailing/ detention than any other correctional response.

Author’s address: Edward Pabon, ACSW Coordinator for Youth Community Service Society 105 E. 22nd St. New York. NY 10010

Notes 1Rosemary Sarri, Under Lock and Key: Juvenile

and Jails and Detention (Ann Arbor, Mich.: Na- tional Assessment of Juvenile Corrections, 1974).

?Statewide Youth Advocacy, Incarcerating Chil- dren: A Study of the New York State Secure Deten- tion System (Rochester, N.Y.: 1981), p. iv.

3NYS Division for Youth, Juvenile Detention in New York State: Policy and Practice (Albany, N.Y.: 1977), p. 11 .

4Pennsylvania Department of Public Welfare, Title 6400 Regulations, Juvenile Detention Facilities, sec. 6401.A.

5Ibid.. p. 12. 6Florida Division of Youth Services, Community

Detention Program Manual (May 1974). ’National Center for the Assessment of Alterna-

tives to Juvenile Justice Processing, Juveniles in Detention Centers and Jails (Washington, D.C.: Office of Juvenile Justice and Delinquency Preven- tion, 1980), p. 5.

%arri, Under Lock and Key, p. 5. Watewide Youth Advocacy, Incarcerating Chil-

lostatewide Youth Advocacy, Institutions, 3, no.

“NYS Division for Youth, Juvenile Detention,

‘2New York Coalition for Juvenile Justice and

‘?Statewide Youth Advocacy, Incarcerating Chil-

14Ibid., p. 11. IsLyle W. Shannon, “Assessing the Relationship of

Adult Criminal Careers to Juvenile Delinquency: A Study of the Three Birth Cohorts,” Iowa Community Research Center, n.d., pp. 15-16.

dren, p. 8.

12 (December 1980): 19.

p. 6.

Youth Services, Newsletter (January 198 1).

dren, p. 9.

16Ibid., p. 7. ”Statewide Youth Advocacy, Incarcerating Chil-

I*Ibid., p. 10. IgZimring, Franklin E., Confronting Youth Crime

dren, p. l l .

(New York: Holmes and Meier, 1978), pp. 65-82.



?"Institute of Judicial Administration, American Bar Association Juvenile Justice Standards: Interim Status (Cambridge, Mass.: Ballinger Publishing Co., 1980, p. 12.

?'Robert Coates, L. Ohlin, and A. Miller, Diversity in a Youth Correctional System (Cambridge, Mass.: Ballinger Publishing Co., 1979), p. 183.

??Richard Kihm. Standardsfor Pre- Trial Deten- tionfor Juveniles (University of Illinois, Community Research Forum, 1980).

23Statewide Youth Advocacy, Incarcerating Chil- dren, p. iv.

24Donnell Pappenfort and Thomas Young, Use of Secure Detention f o r Juveniles and Alternatives for its Use (Washington, D.C.: Office of Juvenile Justice and Delinquency Prevention, 1977).

251bid., p. 31. 26Robert Woodson, Urban Policy and Youth

Crime (Washington, D.C.: American Enterprise In- stitute, 1981).


Documents

The Case for Alternatives to Detention