In re Darryl T

A probation officer representing the interests of the State of California (plaintiff) filed a wardship petition, known as a delinquency petition in other jurisdictions, alleging that Darryl T. (defendant), a 17-year-old, had committed a series of purse snatchings and threatened some of his victims with a knife. Darryl admitted to some of the allegations, and the court found that Darryl was a ward of the court, elsewhere known as a juvenile delinquent. A short time later, the court held a disposition hearing to determine where to place Darryl. One placement under consideration was the state juvenile prison, where juveniles were in custody 24 hours per day. At the disposition hearing, the probation officer testified that he did not seek a psychiatric evaluation for Darryl. The officer also testified that Darryl was unlikely to commit more delinquent acts. Nevertheless, the probation officer recommended Darryl’s commitment to the state juvenile prison because of the gravity of Darryl’s delinquent acts. Darryl introduced evidence that he had never had any trouble with the law until he started snatching purses, and his grades and behavior in school were outstanding. The court did not ascertain the cause for Darryl’s drastic change in behavior and disregarded the suggestion that Darryl should receive a psychiatric evaluation. Without citing evidence, the court opined that Darryl probably committed the purse snatchings because he knew the juvenile court was lenient and would not punish him. The court concluded that Darryl should be punished because of the gravity of his acts and committed Darryl to the state juvenile prison. Darryl appealed the commitment order, arguing that the court should have considered other placements and that commitment to state juvenile prison should be a court’s last resort.