## Facts

- R.S., a sixteen-year-old, had a long history of delinquency, substance abuse, and serious mental-health and cognitive impairments (including organic brain syndrome, emerging antisocial personality disturbance, borderline intellectual functioning, and possible learning disabilities).
- In April 1980, after an adjudication of delinquency for breaking and entering, a circuit court committed R.S. to the West Virginia Industrial School for Boys.
- In April 1981, the superintendent recommended release, concluding that continued confinement at the Industrial School would be of no benefit; R.S. was released to family custody.
- Within days, R.S. was arrested twice for vehicle theft and was again adjudicated delinquent.
- The circuit court recommitted R.S. to the Industrial School and entered an order stating there was no less restrictive alternative, but it did not set out specific supporting facts.
- R.S. sought extraordinary relief to end or alter his confinement, asserting (among other grounds) a right to individualized treatment and to the least restrictive disposition consistent with his needs and public safety.

## Issues

1. Whether juvenile dispositional law requires the committing court to consider and adequately explain, with specific findings, why confinement is the least restrictive alternative consistent with rehabilitation and public safety.
2. Whether a juvenile in state custody—particularly with substantial mental-health impairments—is entitled to individualized treatment reasonably calculated to address therapeutic needs, such that continued placement in an ineffective custodial setting is unlawful.
3. Whether mandamus and habeas corpus are available to compel an appropriate treatment placement and to challenge continued confinement under an inadequate disposition.

## Decision

- The Supreme Court of Appeals of West Virginia granted mandamus directing the committing court to place R.S. in an appropriate residential treatment facility.
- The court conditionally awarded habeas corpus, tying the legality of continued confinement to the prompt provision of a lawful disposition consistent with treatment needs and least-restrictive requirements.
- The court found the circuit court’s conclusory “no less restrictive alternative” finding inadequate because it lacked articulated facts permitting meaningful review.
- The court relied on the juvenile system’s rehabilitative purpose and on professional judgment that continued incarceration at the Industrial School would not benefit R.S.

## Legal Principles

- Juvenile dispositions must be individualized and oriented toward rehabilitation while accounting for public safety.
- The committing court must consider and select the least restrictive dispositional alternative consistent with the juvenile’s needs and community protection.
- A bare conclusion that no less restrictive alternative exists is insufficient; the dispositional order must state supporting facts adequate for review.
- Juveniles in state custody, especially those with significant mental-health impairments, are entitled to treatment consistent with their therapeutic needs; custodial confinement without appropriate treatment may be unlawful.
- Mandamus may compel a juvenile court to carry out its dispositional duties regarding appropriate placement, and habeas corpus may be used to challenge continued confinement when the disposition fails to satisfy governing rehabilitative and least-restrictive standards.

## Conclusion

The court required a fact-supported least-restrictive juvenile disposition and enforced a right to individualized treatment by ordering placement in an appropriate residential treatment facility, granting mandamus and conditionally awarding habeas corpus to prevent continued confinement in an ineffective custodial setting.


State ex rel. R.S. v. Trent, 289 S.E.2d 166 (W. Va. 1982)