## Facts

- A juvenile wardship petition alleged that Darryl T., age 17, committed multiple robberies and related offenses in early 1977, including robberies (Penal Code § 211) and kidnappings (Penal Code § 207), some involving threats or a knife.
- The juvenile court denied a motion to suppress evidence.
- Darryl admitted two robbery counts (one on January 21, 1977, and one on February 4, 1977); the remaining counts were dismissed.
- The record reflected strong prior school performance and no prior delinquency history.
- A probation officer opined Darryl was unlikely to reoffend but recommended commitment to the California Youth Authority (CYA) based on the seriousness and repeated nature of the robberies.
- The juvenile court declared Darryl a ward and ordered CYA commitment, and it also fixed a maximum term of confinement based on the adult maximum for the offenses.

## Issues

1. Whether the juvenile court abused its discretion by committing Darryl to the CYA rather than ordering a less restrictive placement.
2. Whether the juvenile court erred in setting the maximum term of confinement without applying an intervening amendment to Penal Code § 213 that reduced punishment for robbery.

## Decision

- The Court of Appeal affirmed the wardship order and the CYA commitment.
- The court held the juvenile court did not abuse its discretion; substantial evidence supported the conclusion that the seriousness and pattern of the offenses warranted a secure CYA placement.
- The court held the juvenile court erred in calculating the maximum term of confinement under the older, harsher version of Penal Code § 213.
- The case was remanded for the limited purpose of recomputing the maximum confinement term under the amended, more lenient statute.

## Legal Principles

- Juvenile disposition choices, including CYA commitment, are reviewed for abuse of discretion; the appellate court draws all reasonable inferences to support the juvenile court’s order.
- CYA commitment is not governed by an inflexible “last resort” rule; the juvenile court may select CYA when the minor’s conduct and public-safety concerns reasonably support secure custody and structured rehabilitation.
- A psychiatric evaluation is not categorically required before ordering a CYA commitment; the dispositive question is whether the juvenile court had sufficient information to make an informed disposition.
- When a penal statute is amended to lessen punishment and the case is not final, the minor is entitled to the benefit of the ameliorative change when the court sets the maximum term of confinement, absent clear legislative intent to the contrary.

## Conclusion

The appellate court upheld the juvenile court’s discretionary decision to commit a 17-year-old to the CYA based on the seriousness and repeated nature of the robberies, but required recalculation of the maximum confinement term to apply a later statutory reduction in robbery punishment.


In re Darryl T., 81 Cal. App. 3d 874, 146 Cal. Rptr. 771 (Cal. Ct. App. 1978)