L. A. M. began running away from home at the age of 14 and getting into various amounts of trouble. Often, L. A. M. was returned home by the authorities. A petition was filed to declare L. A. M. as a child in need of supervision, and L. A. M. was ordered to be detained at a youth center pending adjudication. L. A. M. was later released into her parent’s custody but subsequently ran away again. A repeating pattern of conduct emerged over the following months. Eventually, a court placed L. A. M. in a foster home and ordered L. A. M. to participate in counseling with her mother. The judge instructed L. A. M. that she would be incarcerated if she left the foster home without informing the psychiatrist, her mother, or her social worker. Two months later, L. A. M. ran away from the foster home without notifying anyone. L. A. M. was apprehended by the authorities and charged with criminal contempt. While awaiting trial, L. A. M. ran away from a receiving home on three separate occasions, despite being ordered to remain at the home. Eventually, L. A. M.’s probation was revoked, because L. A. M. had violated the conditions of her probation by running away from the receiving home. The court directed L. A. M. to be incarcerated at a youth center. L. A. M. appealed. The Supreme Court of Alaska granted certiorari to review.