California Landmark Cases on Juvenile Court Commitment Decision

The Court of Appeal of California's review of a juvenile court's commitment decision is highly deferential: "We review a Division of Juvenile Justice (DJJ) commitment decision only for abuse of discretion, and indulge all reasonable inferences to support the decision of the juvenile court." (In re Asean D. (1993) 14 Cal.App.4th 467, 473; see also In re Angela M. (2003) 111 Cal.App.4th 1392, 1396.) "There is no abuse of discretion where the commitment is supported by substantial evidence on the record." (In re Kevin F. (1989) 213 Cal.App.3d 178, 186; see also In re Tyrone O. (1989) 209 Cal.App.3d 145, 151.) In determining placement in a juvenile delinquency case, the court focuses on the dual concerns of the best interests of the minor and the need to protect the public. In arriving at a disposition, the court considers the probation officer's report and any other relevant and material evidence that may be offered. (Welf. & Inst. Code, 202, subd. (d); In re Jimmy P. (1996) 50 Cal.App.4th 1679, 1684.) The court may consider a commitment to DJJ without first having tried less restrictive placements. (In re Asean D., supra, 14 Cal.App.4th at p. 473.) "Finally, the 1984 amendments to the juvenile court law reflected an increased emphasis on punishment as a tool of rehabilitation, and a concern for the safety of the public. " (Ibid.) "Nonetheless, there must be evidence in the record demonstrating both a probable benefit to the minor by a DJJ commitment and the inappropriateness or ineffectiveness of less restrictive alternatives. " (In re Angela M., supra, 111 Cal.App.4th at p. 1396.)