INTERNATIONAL PERSPECTIVE1

Looking at the policies of other countries provides some perspective on criminal justice in the United States. An international study of 15 countries—Australia, Austria, Belgium, Denmark, England and Wales, France, Germany, Hungary, Italy, Japan, The Netherlands, New Zealand, Russia, Sweden, and Switzerland—notes that all have special provisions for young criminals in their justice systems, although some (such as Denmark, Russia, and Sweden) have no special courts for juveniles. Table 1-1 depicts some of the differences among countries, showing the range in variability for the minimum age of criminal responsibility, the age at which full responsibility as an adult can be assumed, the type of court that handles young people committing crimes, whether such young people can be tried in courts that also try adults, the maximum length of sentencing for a juvenile, and policies regarding incarcerating juveniles with adults.

The United States was not alone in seeing a dramatic increase in violent crime by juveniles in the 1980s and early 1990s. Many European countries and Canada experienced increases in their rates of violent crime, particularly among juveniles (Hagan and Foster, 2000; Pfeiffer, 1998). It is difficult to compare rates across countries, because legal definitions of crime vary from country to country. For example, in Germany, assault is counted as a violent crime only if a weapon is used during the commission of the crime, whereas in England and Wales, the degree of injury to the victim determines whether or not an assault counts as a violent crime. Crime is also measured differently in each country. For example, the United States commonly relies on numbers of arrests to measure crime. In Germany, Austria, and Italy, among other countries, crime is measured by the number of cases solved by police (even if the offender has been apprehended) (Pfeiffer, 1998). Nevertheless, trends in juvenile violent crime appeared similar in many developed countries in the 1980s and early 1990s,2 although the rates were different.

The United States has a high violent crime rate—particularly for homicide—in comparison to other countries, although property crime rates, particularly burglary, are higher than U.S. rates in Canada, England and Wales, and The Netherlands (Hagan and Foster, 2000; Mayhew and White, 1997). In 1994, the violent crime arrest rate (includes homicide, aggravated assault, robbery, and rape) for 13- to 17-year-olds in the United

1  

The panel is indebted to Elmar Weitekamp, Hans-Juergen Kerner, and Gernot Trueg, from whose commissioned paper this material is drawn.

2  

Data from other countries after 1995 were not available to the panel at the time this report was written, so no comparisons for the latter half of the 1990s were possible.



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