States was nearly 800 per 100,000 (Federal Bureau of Investigation, 1995). In England and Wales, about 600 per 100,000 14- to 16-year-olds were convicted or cautioned by the police for violent crimes (homicide, assault, robbery, and rape) in 1994. In Germany, 650 per 100,000 14- to 17-year-olds and in The Netherlands 450 per 100,000 12- to 17-year-olds were suspects of violent crime in 1994 (Pfeiffer, 1998).

Comparing how different countries deal with juvenile offenders is equally challenging. Countries differ in the ages of young people considered legal juveniles, in how juvenile courts are organized, and in the types of institution used to sanction juvenile offenders. As Table 1-1 shows, the minimum age for being considered criminally responsible varies from 7 years (in Switzerland and the Australian state of Tasmania) to 16 (in Belgium and Russia). The age of full criminal responsibility (i.e., the age at which an offender is automatically handled as an adult) is 18 in most of the countries studied by Weitekamp et al. (1999), but is as low as 16 in some Australian states and is 20 in Japan. In the United States, both minimum and maximum ages of juvenile court jurisdiction vary by state, with most states having no minimum age (although in practice, children younger than 10 are seldom seen in juvenile courts). The maximum age of juvenile court jurisdiction is younger in many U.S. states than in the other countries studied, with 3 states having a maximum age of 15, 10 of 16, and the remaining states having a maximum age of 17.

At the same time that states and the federal government in the United States have been moving toward treating juvenile offenders more like adult criminals, many other countries retain a strong rehabilitative stance. The 1988 Youth Court Law of Austria, for example, describes juvenile offending as a normal step in development for which restorative justice, not punishment, is the appropriate response. The Belgium Youth Court Protection Act specifies that the only measures that can be imposed on a juvenile are for his or her care, protection, and education. In New Zealand, since 1989, Family Group Conferences have been used to replace or supplement youth courts for most of the serious criminal cases. In the early 1980s, England and Wales moved toward community-based sanctions for young offenders and away from institutional placements. This trend was reversed in the 1990s, however, when England and Wales reacted to the upswing in juvenile violence in a manner similar to the United States, focusing on the offense, rather than the offender. The U.K. Criminal Justice and Public Order Act of 1994 made it easier to place offenders younger than 15 years in juvenile correctional facilities and extended the maximum length of allowable sentences. The U.K. Crime and Disorder Act of 1998 moved the English juvenile justice system even further toward a punitive, offense-based model.



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