In In re Manuel P. (1989) 215 Cal. App. 3d 48, Division One of the Fourth District upheld section 738 against various constitutional challenges. In so doing, the court stated: "In light of the plenary power of the federal government over immigration and deportation, which we presume the Legislature considered in enacting section 738, we interpret that statute as allowing courts to order such minors released to federal immigration authorities for deportation by the federal government." (Id. at p. 63.) In addition to finding referral to INS authorized by section 738, the court went on to find that referral to INS is the only way to implement section 738 so as to avoid conflicts with federal law: "Because, as we have interpreted the statute, the power over foreign juveniles provided by section 738 is limited to releasing the juvenile to federal authorities for immigration processing, the statute cannot be said to violate standards of uniformity, or directly conflict with the administration of the Immigration and Naturalization Act (INA)." (In re Manuel P. supra, 215 Cal. App. 3d at p. 64.)