Landmark California Cases on Juvenile Court Rehabilitative and Punitive Measures

The juvenile court has broad discretion in determining the appropriate rehabilitative and punitive measures for offenders. ( 202; In re Asean D. (1993) 14 Cal.App.4th 467, 473; In re Michael D. (1987) 188 Cal.App.3d 1392, 1395.) An appellate court will not lightly substitute its judgment for that of the juvenile court. Rather, it must indulge all reasonable inferences in favor of the decision and affirm the decision if it is supported by substantial evidence. (In re Asean D., supra, at p. 473; In re Michael D., supra, at p. 1395.) Substantial evidence is evidence that is "'reasonable, credible, and of solid value--from which a reasonable trier of fact could have made the requisite finding under the governing standard of proof.' " (In re Jorge G. (2004) 117 Cal.App.4th 931, 942.) The weight of the evidence and the credibility of witnesses are the province of the trial court. (In re Heather A. (1996) 52 Cal.App.4th 183, 193.) Although the 1984 amendment places a greater emphasis on punishment and societal protection, rehabilitation remains a critical objective of the juvenile law. (In re Teofilio A. (1989) 210 Cal.App.3d 571, 576; In re Michael D., supra, 188 Cal.App.3d at p. 1396.) A minor's knowledge of the wrongfulness of the minor's act for purposes of Penal Code section 26, paragraph One may not be inferred from the commission of the act itself. (People v. Lewis (2001) 26 Cal.4th 334, 378 (Lewis)) Moreover, a minor's knowledge of the wrongfulness must often be shown by circumstantial evidence. (In re Tony C. (1978) 21 Cal.3d 888, 900 (Tony C.).) A "minor's 'age is a basic and important consideration , and, as recognized by the common law, it is only reasonable to expect that generally the older a child gets and the closer he approaches the age of 14, the more likely it is that he appreciates the wrongfulness of his acts.' " (Lewis, at p. 378.) Other pertinent considerations include the minor's conduct, knowledge, and the attendant circumstances of the crime, such as its preparation, the particular method of its commission, and circumstances demonstrating a consciousness of guilt, such as concealment, or false statements regarding the offense. (Cf. Id. at pp. 378-379; Tony C., at p. 900.)