## Facts

- A minor was adjudicated delinquent and placed on probation.
- After probation was revoked, a probation officer prepared a predisposition report recommending continued probation with intensive supervision and placement with foster parents.
- The juvenile court adopted the recommendations, continuing probation and ordering foster placement.
- At the disposition hearing, the minor’s parents appeared with counsel and requested (1) access to the predisposition report to challenge its accuracy and basis, and (2) permission to cross-examine the probation officer about the investigation and recommendations.
- The juvenile court denied both requests, ruling the parents lacked standing in the delinquency proceeding.
- The parents appealed in their own right under A.R.S. § 8-236; the minor did not appeal.

## Issues

1. Whether a juvenile’s parents are “aggrieved parties” under A.R.S. § 8-236 with an independent right to appeal a final order entered in a delinquency proceeding.
2. Whether the parents were entitled to review the predisposition report and cross-examine the probation officer at the delinquency disposition hearing.

## Decision

- The court dismissed the appeal for lack of appellate jurisdiction.
- The court held the parents were not “aggrieved parties” under A.R.S. § 8-236 in a delinquency proceeding.
- Because the parents lacked statutory authority to appeal, the court did not reach the merits of their claims regarding access to the predisposition report or cross-examination of the probation officer.

## Legal Principles

- Under A.R.S. § 8-236, only an “aggrieved party” may appeal from a final juvenile-court order.
- In a juvenile delinquency proceeding, the parties for purposes of appeal are the State and the minor; the minor’s parents are not parties in their own right.
- A person is not an “aggrieved party” entitled to appeal where the person’s legal status or rights are not adjudicated as a party within the proceeding.

## Conclusion

The court dismissed the parents’ appeal, holding that in delinquency matters the statutory right to appeal belongs to the State and the juvenile, not the parents, and therefore the parents could not independently challenge disposition-related procedural rulings on appeal.


In re Pima Cnty. Delinquency Action No. 90101-1, 154 Ariz. 493, 744 P.2d 20 (Ct. App. 1987)