offense beyond a reasonable doubt. See Apprendi, 120 S.Ct. at 2366; In re Winship, 397 U.S. 358, 364, 90 S.Ct. 1068, 25 L.Ed.2d 368 (1970). By contrast, whatever right a child may have to be treated as a child within the juvenile justice system is a statutory, not a constitutional, right. See Kent v. United States, 383 U.S. 541, 547-48, 86 S.Ct. 1045, 16 L.Ed.2d 84 (1966). The United States Supreme Court has drawn a clear line between the process due during an adjudication of delinquency or guilt and the lesser process due during an amenability hearing. Compare In re Winship, 397 U.S. at 365, 90 S.Ct. 1068 (“The same considerations that demand extreme caution in fact-finding to protect the innocent adult apply as well to the innocent child.”), with Kent, 383 U.S. at 562, 86 S.Ct. 1045 (<HOLDING>), and Breed v. Jones, 421 U.S. 519, 537, 95
holding failure to raise issue of improper measure of damages in trial court waived review of complaints that proper measure of damages was not submitted to jury and that plaintiff failed to present evidence on the proper measure holding that the facts did not measure up to the standard expressed for determining procedural due process holding that consistent with due process telephone hearings may be conducted to resolve interstate unemployment compensation claims because abolition of such hearings would not materially reduce the risk of erroneous deprivations and such hearings are a reasonable means of conserving fiscal and administrative resources holding that a fair tribunal is a basic requirement of due process holding that amenability hearings must measure up to the essentials of due process and fair treatment