H. M. L. v. State
In H. M. L. v. State, 131 Ariz. 385, 641 P.2d 873 (App. 1981), the juvenile court ordered the juvenile committed to Adobe Mountain School for evaluation, and if necessary, care and treatment for up to 90 days. H. M. L., 131 Ariz. at 387, 641 P.2d at 875.
In addition, "the commitment was not to commence until 'immediately after the termination of . . . the semester of school.'" Id.
The Court of Appeals held that the juvenile court erred in the disposition. Id. at 388, 641 P.2d at 876.
The result was a remand for the juvenile court to "have the opportunity to reconsider its disposition." Id.
The H. M. L. court did not further explain why it remanded to reconsider the entire disposition.
However, the juvenile had been adjudicated delinquent for simple assault and disturbing the peace in a single "episode of juvenile 'gang fighting.'" Id. at 386, 641 P.2d at 874.
The juvenile apparently had no prior charges or delinquency adjudications.