## Facts

- A juvenile on probation was taken into custody after allegedly disturbing the peace and releasing a large German Shepherd to attack police.
- A formal complaint describing the conduct was filed in juvenile court and referred to a juvenile probation officer.
- The probation officer elected to hold the complaint for possible informal adjustment under the juvenile rules.
- Separately, the county attorney received a police report about the incident and filed a formal petition alleging the juvenile violated probation by disturbing the peace.
- The juvenile moved to dismiss, arguing the probation officer’s adjustment decision barred the county attorney from filing a petition based on the same conduct; the juvenile court denied the motion.
- After a hearing, the juvenile court found a probation violation and continued the juvenile on probation.
- The juvenile appealed on procedural and constitutional grounds, not on the sufficiency of evidence.

## Issues

1. Whether a juvenile probation officer’s decision to hold a complaint for possible adjustment precludes the county attorney from filing a juvenile petition based on the same incident.
2. Whether the juvenile petition-filing procedure violates equal protection because it does not require a probable-cause determination comparable to adult criminal prosecutions.

## Decision

- The Arizona Supreme Court granted review, vacated the court of appeals’ decision, and affirmed the juvenile court’s judgment.
- A probation officer’s informal adjustment decision does not bar the county attorney from filing a formal petition.
- The juvenile petition procedure does not violate equal protection merely because it differs from adult probable-cause screening mechanisms.

## Legal Principles

- A juvenile probation officer’s authority to consider informal adjustment does not displace the county attorney’s independent authority to initiate formal juvenile proceedings, including probation-violation petitions.
- Juvenile court is a distinct system with different purposes and procedures from adult criminal prosecution; procedural differences are constitutionally permissible absent a showing of unconstitutional arbitrariness or unfairness.
- Equal protection does not require identical pretrial probable-cause procedures for juveniles and adults when the differing procedural framework is justified by the juvenile system’s separate structure and aims.

## Conclusion

The court held that the prosecutor could file a probation-violation petition notwithstanding the probation officer’s decision to pursue possible informal adjustment, and that the juvenile petition process—though lacking an adult-style probable-cause determination—did not deny equal protection.


In re Appeal in Maricopa Cnty. Juv. Action No. J-81405-S, 122 Ariz. 252, 594 P.2d 506 (1979)