On September 1, 1994, in Chicago, Robert Sandifer was found face down under a railroad viaduct with two bullets in the back of his head. This eleven year old, nicknamed "Yummy" for his love of cookies, had a rap sheet listing twenty-three felonies. Tragically, a week before his death Robert was suspected of spraying bullets from a semi-automatic pistol into two groups of youths. The Robert Sandifer saga is representative of the growing problem of juvenile crime in the United States today. In fact, the number of youths under age eighteen arrested for murder has more than doubled since the 1980s. In response, the U.S. legislature addressed the problem of juvenile crime in the Violent Crime Control and Law Enforcement Act of 1994 [hereinafter Crime Law].
Sharon K. Hamric-Weis, The Trend of Juvenile Justice in the United States, England, and Ireland, 13 Penn St. Int'l L. Rev. 567 (1995).