## Facts

- Aline D., a 16-year-old minor, was a longstanding ward of the juvenile court with an absent father and a mother who rejected her.
- She had an IQ of 67 and a history of assaultive conduct and association with juvenile gangs.
- After wardship, she was placed in multiple local or private programs, including a juvenile hall family treatment program, community day-care screening, and various residential placements; each placement failed due to behavioral problems, gang activity, drug use, stealing, or inability to qualify.
- She was repeatedly returned to juvenile hall, a facility intended for temporary detention rather than long-term treatment.
- At the final dispositional hearing, the juvenile court (acting through a referee) considered probation and psychiatric reports indicating Aline was not an appropriate candidate for commitment to the California Youth Authority (CYA).
- The referee nevertheless ordered commitment to the CYA because no suitable alternative placement appeared available and the referee feared she would become homeless.

## Issues

1. Whether Welfare and Institutions Code § 734 permits commitment of a ward to the CYA when the court doubts the minor will benefit and commits the minor only because no other placement is available.
2. Whether the statutory “benefit” requirement in § 734 limits juvenile court dispositional discretion in ordering a CYA commitment.

## Decision

- The California Supreme Court reversed the CYA commitment order.
- The court held the commitment was improper because the record showed it was ordered solely due to the absence of alternative placements, despite expressed doubt that Aline would benefit.
- The case was remanded for reconsideration of disposition consistent with § 734’s requirements.

## Legal Principles

- A CYA commitment requires an affirmative judicial finding that the court is “fully satisfied” the minor will benefit from the reformatory educational discipline or other treatment provided by the Youth Authority. (Welf. & Inst. Code § 734.)
- A juvenile court may not use the CYA as a placement of last resort based only on the unavailability of other facilities.
- Dispositional discretion in juvenile court is constrained by statutory predicates; when the court expresses doubt about benefit, the § 734 prerequisite for CYA commitment is not met.
- On remand, the juvenile court must select a disposition based on statutory criteria and evidence of likely benefit if CYA commitment is considered.

## Conclusion

The court set aside the CYA commitment because § 734 requires a finding of likely benefit to the minor, and a commitment cannot rest solely on the lack of other placement options; the matter was returned to the juvenile court for a new dispositional determination under that standard.


In re Aline D., 536 P.2d 65 (Cal. 1975)