## Facts

- Police responded to a report of an ongoing rape in a public park.
- Officers found a woman being raped by another minor; Michael D. was near the victim’s head and appeared to be holding her down.
- Medical evidence showed the victim had lacerations and bruises consistent with attempted strangulation.
- Michael later admitted one count of sexual battery (Cal. Penal Code § 243.4(a)) in a juvenile proceeding under Welfare and Institutions Code § 602.
- At disposition, the defense presented expert testimony favoring probation and parental custody with therapy, warning that a California Youth Authority (CYA) commitment could increase delinquent peer identification.
- A court-appointed psychologist opined Michael had poor judgment, was beyond reasonable authority control, and required firm limits in a structured program.
- The juvenile court declared Michael a ward of the court and committed him to CYA, citing the seriousness of the offense, public safety, and the need for structured intervention.
- Michael appealed, arguing the juvenile court abused its discretion by selecting CYA over less restrictive alternatives.

## Issues

1. Whether a juvenile court abuses its discretion by committing a minor to CYA based in part on punishment and public safety considerations, where the record also supports probable rehabilitative benefit to the minor.

## Decision

- The Court of Appeal affirmed the CYA commitment.
- It held that a CYA commitment may be based on punishment and public safety so long as it will also provide rehabilitative benefit to the minor.
- The court found substantial evidence supporting the juvenile court’s conclusion that CYA’s structured setting would likely benefit Michael, notwithstanding conflicting defense expert opinions.
- Given the offense’s violence and the minor’s apparent lack of remorse, the juvenile court acted within its discretion in choosing a restrictive placement.

## Legal Principles

- A juvenile court may commit a minor to CYA when the disposition serves rehabilitation and also accounts for punishment and protection of the public, provided there is evidence of probable rehabilitative benefit.
- Dispositional orders in juvenile cases are reviewed for abuse of discretion; an appellate court will not substitute its judgment where the juvenile court’s decision has a rational basis supported by the record.
- In selecting a placement, a juvenile court may weigh the seriousness of the offense, public safety risk, the minor’s attitude and behavior, and expert evaluations when determining whether a structured environment is necessary.

## Conclusion

The court upheld the CYA commitment because juvenile dispositions may consider punitive and public-safety aims in addition to rehabilitation, and the record supported that the structured CYA program offered probable rehabilitative benefit in light of the offense and expert assessment.


In re Michael D., 188 Cal. App. 3d 1392, 234 Cal. Rptr. 103 (Cal. Ct. App. 1987)