In re Ricardo A

In In re Ricardo A. (1995) 32 Cal. App. 4th 1190, held that a delinquent section 602 ward could not be found in criminal misdemeanor contempt ( Pen. Code, 166) for violations of probation. Rather, such violations could be alleged as contempts only under section 213, the specific juvenile court contempt section used in our case. The court followed Mary D., noting that, in 1986, the Legislature amended the juvenile court law to "generally require a supplemental petition under section 777 to revoke probation. Courts have rejected the use of contempt proceedings and other devices to evade the requirements of section 777. Citations. " (32 Cal. App. 4th at p. 1197.) However, the court refused to follow a case which held that an adult probationer could not be held in contempt for probation violations, because of "the significant differences between the adult probation system and the juvenile probation system." ( Id. at p. 1200, 38 Cal. Rptr. 2d 586.)