The Supreme Court of the United States has held that a Maryland juvenile rule that allows the state to file exceptions to a master's proposed findings and recommendations with a juvenile judge does not violate the double jeopardy clause even though the juvenile judge is free to accept, reject, or modify the proposals or to supplement the record, since the master's hearing and review by the judge constitutes a single proceeding.
Swisher v. Brady, 98 S. Ct. 2699 (1978).
Christine L. Donohue,
Constitutional Law - Double Jeopardy - Juvenile Court Procedure - State Exceptions to Master's Proposals,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol17/iss3/16