In In re Mary D. (1979) 95 Cal. App. 3d 34, the minor was declared a delinquent section 602 ward based on committing misdemeanor vandalism ( Pen. Code, 594), carrying a maximum confinement time of six months, and placed on probation. When she violated a term of probation by conduct that otherwise did not constitute a crime, a supplemental petition alleging criminal contempt with a maximum six-month penalty ( Pen. Code, 166) was found true. The trial court ordered the minor confined for six months for the contempt. The Mary D. court reversed, holding that the minor could have been confined for a probation violation for up to six months on the vandalism. However, additional confinement time could not be added for noncriminal conduct by dressing it up as a criminal contempt. To do so would elevate section 601 conduct into section 602 status and would be "a different aspect of the same bootstrapping technique, one which appears to us to be subject to similar criticism." (95 Cal. App. 3d at p. 38.)