The Supreme Court of the United States has held that where a juvenile is charged with the commission of a delinquent offense for which institutional confinement may be imposed, due process requires that the charges against him be proved beyond a reasonable doubt.
In re Winship, 397 U.S. 358 (1970).
M. L. Shields III,
Constitutional Law - Burden of Proof in a Juvenile Delinquency Proceeding,
Duq. L. Rev.
Available at: https://dsc.duq.edu/dlr/vol9/iss4/10