In re M.F.
Annotate this CaseIn May 2015, police detained defendant M.F. at his high school after he gave one of his teachers a letter stating that she "should be worried about getting shot." When detained, he was wearing an empty holster. The police searched M.F.'s backpack and found journals that described a plan to kill individuals associated with schools that he had attended. The journals also contained a list of supplies that he would need to carry out his plan and "hit lists" of potential victims, with various types of "punishments" (such as wound, torture, death, rape, or a combination thereof) next to each name. In addition, one journal entry indicated that M.F. had been "faking it" while participating in anger management and counseling following his 2013 expulsion. At home, police searched M.F.'s bedroom and found 20 rounds of live ammunition, several replica firearms, gun magazines, gun cleaning equipment and gun holsters, including one for a Glock firearm, a handgun case, a folding knife, black ski masks and a balaclava. Police also found tactical gear, including a ballistic helmet, vest and armor plates. Several items found in M.F.'s bedroom had been checked off on his supply list. M.F. told police that he had been involved in a militia for several years, admitted having borrowed a Glock and a rifle from militia members, and that the militia had given him body armor, which he said he used "mostly" for his job as a paintball referee. He claimed that his journal entries were intended to be cathartic and he had no intention of physically harming anyone. Regarding his participation in anger management and decision-making counseling in 2014, he admitted that the programs had been ineffective in helping him appropriately channel his anger. M.F. appealed a juvenile court's disposition order declaring him a ward of the court, committing him to a residential program, and setting probation conditions. He contended the court erred by: (1) admitting cumulative and prejudicial testimony and exhibits at the disposition hearing; (2) committing him to a 480-day residential program; (3) imposing an unconstitutionally overbroad probation condition restricting his possession of electronic devices; (4) designating one of his offenses as a felony without a proper section 702 finding; and (5) failing to deduct his predisposition custody credits when calculating his maximum term of confinement. The Court of Appeal concluded the juvenile court erred in imposing an overly broad probation condition regarding electronic devices and in failing to deduct predisposition custody credits when determining M.F.'s maximum time of confinement. The Court reversed the disposition order in part, and remanded for the juvenile court to modify its order to include: (1) a more narrowly tailored probation condition, and (2) a deduction of M.F.'s predisposition custody credits in its determination of his maximum period of confinement. In all other respects, the Court affirmed the order.
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