Distinguishing Juvenile Law and Juvenile Education: Undoing the School-to-Prison Pipeline Approved in “In re S.F.”

Anna Manogue

In In re S.F., the then-Court of Appeals of Maryland held that a juvenile probation condition requiring a child to “attend school regularly without suspension[]” is not impermissibly vague. Although the court correctly applied Maryland law to uphold the condition, the incorporation of school suspensions into juvenile court sanctions exposes Maryland’s schoolchildren to compounding forms of arbitrary treatment. By affirming the role of juvenile courts in school-based punishments, the court undercut the purpose of school discipline and approved the school-to-prison pipeline in Maryland. The General Assembly should amend the Juvenile Causes Statute to curtail the use of no-suspension conditions of juvenile probation.