Because delinquency hearings are labeled as “civil” rather than criminal, some rights that are guaranteed to adults in criminal proceedings do not extend to youth tried in juvenile court. When determining which constitutional rights should be incorporated into the juvenile court system, courts consider the Due Process Clause’s guarantee of “fundamental fairness.” Under this “Fundamental Fairness Test,” the Supreme Court found that the Sixth Amendment’s right to trial by jury does not extend to juvenile courts . . . However, the Supreme Court’s decisions on juvenile adjudication were made in the 1960s and 1970s, “prior to the explicit movement towards punitive juvenile justice.”