## Facts

- Miguel R., a juvenile, was adjudicated delinquent for Class 6 felony possession of marijuana.
- At disposition, the juvenile court placed Miguel on standard probation and required participation in the county juvenile drug court as a special probation term.
- Jose J., a juvenile, was adjudicated delinquent for Class 6 felony theft and placed on standard probation.
- After repeated positive marijuana tests, the court held violation-of-probation proceedings for Jose, ordered him to “shadow” drug court while considering less restrictive options, and later ordered full participation in drug court over his objection.
- The record showed both juveniles received verbal and written notice of hearings, written probation conditions, and warnings that probation violations could result in detention (up to one year).

## Issues

1. Whether the juvenile court abused its discretion or exceeded statutory authority by ordering involuntary participation in juvenile drug court as a special term of probation.
2. Whether mandatory drug court participation and drug court sanctions violated due process because of allegedly insufficient notice and hearing protections.
3. Whether drug court requirements compelled self-incrimination in violation of the Fifth Amendment (and state counterpart).
4. Whether assigning some juveniles to drug court while others remain on standard probation violated equal protection.

## Decision

- The Court of Appeals consolidated the cases and affirmed the juvenile court orders.
- The juvenile court acted within its broad authority to impose probation conditions reasonably related to rehabilitation and did not abuse its discretion by requiring drug court participation.
- On the record presented, the juveniles received sufficient notice and process connected to their adjudications, dispositions, and probation conditions; no due process violation was shown.
- No self-incrimination violation was established because the record did not show compelled statements were used to increase punishment beyond the existing disposition, and the privilege was not timely invoked when implicated.
- No equal protection violation was shown because individualized juvenile dispositions may include drug court when rationally related to rehabilitative goals.

## Legal Principles

- Juvenile courts have broad discretion to set probation terms after delinquency adjudication; a condition will be upheld if it is reasonably related to probation’s rehabilitative purpose and does not violate fundamental rights.
- Drug court participation may be imposed as a special condition of juvenile probation when supported by the juvenile’s offense or drug-related conduct and tied to rehabilitation.
- Due process in this setting is satisfied when the juvenile has notice of hearings, probation conditions, and potential detention consequences; drug court sanctions within the probation framework do not inherently require separate, formal proceedings absent a record showing inadequate opportunity to be heard.
- The privilege against self-incrimination is not violated without a showing that compelled statements were used to impose greater punishment than already authorized by the disposition, and claims may fail where the privilege was not properly invoked at the relevant time.
- Equal protection permits differential probation conditions, including drug court assignment, when the distinction is rationally related to legitimate rehabilitative objectives.

## Conclusion

The appellate court upheld juvenile drug court as a permissible probation condition and rejected due process, self-incrimination, and equal protection challenges because the program was rationally related to rehabilitation and the record did not show a constitutional violation.


In re Miguel R., 204 Ariz. 328, 63 P.3d 1065 (Ct. App. 2003)