In re J.C.
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Sacramento Police received a call from Kennedy High School that there was "an uncontrollable, irate student in the hallways." While in the principal's office, the minor called his mother; he became more and more irate as he talked, "screaming [and] yelling" and pacing the floor. The responding officer asked the minor to sit down and calm down, but the minor did not listen. The minor slammed or threw the phone down on the table. About three to five seconds after the minor failed to obey the order to sit down and calm down, the officer detained him "based on [the officer's] safety and safety of the school and also the [minor]'s." The officer advised the minor he was being detained and ordered him to put his hands on his head with his fingers interlaced. In an attempt to put a control hold on the minor by grabbing the minor's interlaced hands with one hand and grabbing the minor's elbow from underneath with the other hand, the minor turned, pulled away, and started to walk away. The officer performed an arm bar takedown on the minor and detained him on the floor; he then handcuffed him and took him out to his squad car. After obtaining briefing from the parties on the legal and factual issues, the juvenile court issued a ruling sustaining both charges. As to the resisting charge, the court found that the minor's conduct before his detention was sufficient to justify the detention. The minor appealed the order of the juvenile court declaring him a ward of the court, arguing that one of the two allegations the court sustained was supported by sufficient evidence and that the other was founded on an unconstitutional statute. Finding no reversible error, the Court of Appeal affirmed.
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