In 1959, 14-year-old Bobby Gallegos was convicted of first-degree murder in Colorado. According to the U.S. Supreme Court opinion in Gallegos v. Colorado, the child and another juvenile tricked an elderly man into letting them into his hotel room, where they assaulted him, stole $13 from him and fled.
Less than 2 weeks later, Gallegos was caught by police and admitted to the assault and robbery. Just a few weeks after that, he was convicted in a juvenile court of “assault to injure.”
After his sentencing, the elderly man he assaulted died, which led to Gallegos being tried in state court—for first-degree murder.
The court found him guilty, but the evidence that underpinned his conviction would prove problematic.
The opinion noted that the crucial evidence at the trial was a confession that Gallegos had signed before his victim died. But that wasn’t the only issue. He had also been held for five days without seeing a lawyer, family or friendly adult, and he had not been brought before a judge during that entire time.
The case first went to the state Supreme Court, which affirmed the decision. But in April 1962, the case was heard before the Warren Court.
Justice William Douglas delivered the opinion of the court. The opinion noted that Gallegos’ detention, along with the lack of visitation despite his mother’s attempt to visit him, gave the case an “ominous cast.” It further noted that a 14-year-old boy didn’t have the capacity to understand the consequences of being held solely by the police for multiple days.
The opinion stated that “to allow this conviction to stand, would, in effect, be to treat him as if he had no constitutional rights.”
The nation’s high court found that, given the totality of the circumstances, the formal conviction had been obtained in violation of due process and reversed the decision.
But it was a close decision. Two justices took no part in the case, and it was decided by a 4-3 margin.
While the first-degree murder conviction was overturned, Gallegos ultimately agreed to a plea deal. He pleaded no contest to voluntary manslaughter in 1964, according to a Rocky Mountain News article.