In re Miguel R.

Miguel R. and Jose J. (defendants) were two juveniles in Arizona (plaintiff) who pleaded delinquent to Class 6 felonies for possession of marijuana and theft, respectively. After an initial hearing, a subsequent hearing, and a disposition hearing, a juvenile court assigned Miguel to standard probation and added participation in drug court as a special term. Jose was initially placed on standard probation, which he violated by testing positive for marijuana multiple times. At an initial violation-of-probation hearing, the juvenile court ordered Jose to shadow drug court for one month, and the court delayed making a final disposition during this time, in which the court considered alternatives that were less restrictive. However, Jose continued to test positive. At a final violation-of-probation hearing, the juvenile court ordered Jose’s participation in drug court over his objections, finding that the other alternatives were not suitable in Jose’s case. Both Miguel and Jose were provided with verbal and written notice of hearings, conditions of probation, and the potential for detention for one year upon violation of probation. Miguel and Jose appealed. On appeal, Miguel and Jose first argued that mandated participation in drug court did not encourage rehabilitation, was not rationally related to that objective, and was not warranted based on the facts in their cases. The appellate court found these claims without merit and considered the constitutional claims. Regarding due process, Miguel and Jose claimed a violation based on not receiving written notice, a hearing, and a chance to offer evidence after they violated a condition of drug court. Regarding the right against self-incrimination, Miguel and Jose argued that admissions they made in drug court or to their probation officers could be used to impose a detention that had been deferred or to enhance their sentences. This argument failed because there was no indication that particular statements were so used, and Miguel did not invoke a right against incriminating himself until after his disposition. Also, the dispositions for both juveniles, including possible detention, had already been imposed, so there was no enhancement. Finally, Miguel and Jose claimed a violation of equal protection because all juvenile delinquents were not required to participate in drug court.