In re Miguel C.
Annotate this CaseBefore committing a minor to the California Division of Juvenile Justice (DJJ), the state’s most restrictive placement for its most severe juvenile offenders, the law required the juvenile court to find both that the placement would probably benefit the minor, and that less restrictive options would be either ineffective or inappropriate. In this case, we address an issue anticipated, but not decided, in In re Carlos J., 22 Cal.App.5th 1 (2018), namely, what constitutes substantial evidence to support a DJJ commitment when the minor has submitted reliable evidence that such a placement would undermine the minor’s specific rehabilitative needs, and where the minor’s own history does not demonstrate that less restrictive options would not work? The Court of Appeal concluded the State had to provide some contrary evidence that would enable the juvenile court to make a comparative analysis of the placement options before it concludes the minor will probably benefit from DJJ, and that less restrictive options would be ineffective or inappropriate. Here, expert testimony indicated that placing this minor in DJJ would be counterproductive because it would likely assure his entrenchment in gang culture and, due to the ready availability of drugs in DJJ facilities, undermine efforts to treat and improve a significant substance abuse disorder that led to a single episode of violent criminal behavior over the course of a few hours. Beyond identifying that substance abuse treatment was available at DJJ, the State introduced no responsive evidence. So, as in Carlos J., the Court reversed and remanded in an opinion that focused "not on the substantive correctness of the juvenile court’s conclusion, but on the procedural requirement that there be evidence in the record to support whatever conclusion the court reaches." On remand, given intervening changes to the juvenile court law, the trial court had to first make a threshold finding as to whether juvenile justice realignment now precluded commitment to DJJ.
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