عنوان مقاله [English]
Determining the minimum age of criminal responsibility has always been one of the controversial issues of the Convention on the Rights of the Child. This research aims to compare the criminal responsibility of children in Iranian and American law by using the descriptive-library research method and the data collection tool and the conclusions have been made. In 2012, the legislator made important changes in the field of criminal responsibility of children and determining the minimum age of their criminal responsibility. First, a distinction was made between the minimum age of criminal responsibility and the age of criminal maturity in Ta'ziri crimes, and then the freedom of action of the judges was increased to not implement the limit and retribution in the case of perpetrators under the age of 18. In the American federal law, there is no specific minimum for the criminal responsibility of children, and it has left this issue to the state law, which varies from 7 years to 21 years, but based on the general rules of the common law and children under ten years of age from criminal responsibility. They are completely conductive. On the contrary, teenagers between ten and eighteen years of age have the same criminal responsibility as adults, but the way they are treated is different from the treatment of adults, so that the main emphasis is on reform and education.