Criticism of Fortas's opinion began with the dissent of Justice Potter Stewart. His concern, and the concern of many, was that imposition of the new procedures would return the treatment of delinquent juveniles to the old adversarial system. While that point was well taken, the experience of Jerry Gault lent credence to Justice Fortas's comment that "unbridled discretion, however benevolently motivated, is frequently a poor substitute for principle and procedure."

Source:

John R. Sutton, Stubborn Children: Controlling Delinquency in the United States, 1640-1981 (Berkeley: University of California Press, 1988).