## Facts

- Eric J., a minor, had previously been adjudged a ward of the juvenile court under Welfare and Institutions Code § 602.
- In the proceeding at issue, the juvenile court continued wardship, found Eric committed burglary and violated probation, and committed him to the California Youth Authority.
- The juvenile court set a maximum period of physical confinement of three and one-half years for burglary plus an additional six months for a probation-related contempt, totaling four years.
- Before the dispositional order, Eric spent time in custody in juvenile hall (precommitment/predisposition custody).
- The dispute concerned whether precommitment custody time must be credited against the maximum term of physical confinement permitted under Welfare and Institutions Code § 726.

## Issues

1. Whether Welfare and Institutions Code § 726 requires credit for predisposition (precommitment) custody against the maximum term of physical confinement.
2. Whether the obligation to award such credit in juvenile proceedings derives from Penal Code § 2900.5 or from Welfare and Institutions Code § 726.

## Decision

- The California Supreme Court held that, to enforce § 726’s limit that a minor not be held in physical confinement longer than the adult maximum for the same offenses, the minor must receive credit for time spent in custody before the dispositional order.
- The court found it unnecessary to decide whether Penal Code § 2900.5 applies directly to juvenile wardship proceedings because § 726 itself requires the credit.
- The effect of the holding is that the maximum permissible confinement includes both precommitment and postcommitment confinement; precommitment custody reduces the remaining time that may be served under the § 726 maximum.

## Legal Principles

- Welfare and Institutions Code § 726 imposes an absolute ceiling on a ward’s total period of physical confinement, tied to the maximum imprisonment term that could be imposed on an adult for the same offense(s).
- To prevent exceeding that statutory ceiling, juvenile courts must credit all time spent in predisposition/precommitment custody against the § 726 maximum.
- The credit requirement in this context is grounded in § 726’s confinement limitation, even if adult presentence-credit principles are analogous.

## Conclusion

The court interpreted Welfare and Institutions Code § 726 to cap a juvenile’s total physical confinement at the adult maximum for the same offenses and required credit for precommitment custody to ensure the minor’s combined pre- and postdisposition confinement does not exceed that limit.


In re Eric J., 601 P.2d 549 (Cal. 1979)