In re Michael D.

Michael D. (defendant) was a juvenile who was caught in the act of raping a woman on the playground of a local park. The woman’s bruises also suggested that Michael had attempted to strangle her. After the assault, Michael demonstrated little remorse over what he had done or concern for the woman. Michael admitted to committing sexual battery. A probation report determined that the outrageousness of Michael’s behavior was sufficient in itself to warrant commitment to the California Youth Authority (CYA). The report recommended commitment after objectively weighing the factors so that the community could be protected and Michael could atone for such a brutal crime. Indeed, a court-appointed psychologist determined that Michael could not be controlled by his parents. Additionally, Michael’s own private psychologist was doubtful that Michael’s parents could implement the restrictions on his behavior needed for his rehabilitation. Michael’s moral and social judgment were poor, necessitating strong guidance. Michael also acknowledged drug and alcohol abuse. A juvenile court held Michael guilty of a brutal crime and determined that he was a threat to society. Michael’s substance abuse was a substantial factor in the court’s ruling. The juvenile court reasoned that commitment would serve both Michael’s and society’s interests and enable Michael to benefit from the CYA’s reformatory discipline. Michael appealed the court’s commitment order, arguing that: (1) he was being confined improperly for retribution instead of rehabilitation; (2) the court’s assessment of alternatives that were less restrictive was not proper; and (3) he could not benefit from being committed.