## Facts

- Scott L. was a 16-year-old high school student who regularly sold marijuana to other students, acting as a middleman.
- Scott was adjudicated delinquent after he unwittingly sold marijuana to an undercover narcotics agent.
- At disposition, the juvenile court committed Scott to Spring Mountain Youth Camp, a custodial facility described as a place of involuntary confinement and punitive incarceration.
- The juvenile court judge stated on the record that the **sole reason** for ordering a punitive disposition was the deterrent effect it would have on other children in the community.
- The judge explained that when juveniles sell drugs to other juveniles, other youth observe the conduct and talk about who is removed from school and the community; removing a youth drug dealer for at least a school semester would deter similar conduct by peers.
- The record also reflected that Spring Mountain Youth Camp provided high school classes and rehabilitative/treatment programming for juveniles.
- The juvenile court concluded that, despite the punitive nature of the placement, the commitment would serve Scott’s best interests.
- Scott appealed, arguing the juvenile court lacked adequate cause to depart from the presumption favoring home placement and lacked sufficient reason to confine him.

## Issues

1. Whether the juvenile court had sufficient reason to depart from the presumption that a delinquent child should be placed at home and instead order confinement at Spring Mountain Youth Camp.
2. Whether a punitive, custodial juvenile disposition may be justified primarily by deterrence of the juvenile and other youth, consistent with Nevada juvenile law and prior Nevada Supreme Court authority (including *Glenda Kay S., A Minor v. State*).

## Decision

- The Supreme Court of Nevada **affirmed** the juvenile court’s dispositional order committing Scott to Spring Mountain Youth Camp.
- The court approved the juvenile judge’s stated reasons, noting the judge explained the basis for the punitive placement in open court.
- The court treated deterrence—particularly deterring school-based, peer-to-peer drug dealing—as a legitimate reason supporting a custodial, punitive disposition on this record.
- The court rejected Scott’s claim that the home-placement presumption barred confinement here, concluding the juvenile court’s articulated rationale was sufficient to justify the departure.

## Legal Principles

- Nevada juvenile dispositions generally start from a presumption favoring placement in the child’s home rather than institutional confinement.
- A commitment to a custodial facility that functions as punitive incarceration is permissible only when the juvenile court states specific reasons supporting the need for that placement, rather than treating confinement as the default.
- Deterrence may be considered in juvenile disposition decisions, including deterrence of other youth who observe the consequences of drug dealing at school and in the community.
- The seriousness and repeated nature of delinquent conduct can justify a more restrictive placement, particularly where the juvenile court explains why a custodial commitment is warranted and how the placement serves the child’s best interests.

## Conclusion

In *Scott L. v. State*, the Nevada Supreme Court affirmed a juvenile court’s decision to commit a 16-year-old, heavily involved in selling marijuana at school, to Spring Mountain Youth Camp. Even though the judge stated deterrence was the sole reason for imposing a punitive placement, the court held that deterrence and the public interest in stopping juvenile drug dealing could supply sufficient justification to depart from the usual preference for home placement, where the reasons are stated on the record and the placement includes educational and rehabilitative programming.


Scott L. v. State, 760 P.2d 134 (1988)