A.T. v. Superior Court of Solano County
10 Cal. App. 5th 314
| Cal. Ct. App. | 2017Background
- 14-year-old A.T., with no prior delinquent history, was arrested after police found a small handgun in a trunk during a vehicle stop; charged by juvenile petition with theft and firearm offenses.
- A.T. and her brother (codefendant) were joined over their objections; prosecutor offered a package-deal plea requiring both minors to admit charges for mutual formal probation.
- A.T. repeatedly sought release to her mother's custody; the juvenile court denied release several times, citing safety concerns about downtown Vallejo and conditioning release on resolution of the case.
- After 15–16 days in custody and after the court twice declined to grant probation discretion to release her, A.T. pleaded guilty to a misdemeanor and was released to home supervision; she then filed a writ petition and moved to withdraw her plea.
- The appellate court exercised supervisory jurisdiction, found the record showed detention had been used to pressure A.T. to accept the package plea and that the court improperly relied on its subjective view of the mother’s neighborhood instead of individualized, evidence-based findings.
- The appellate court directed the juvenile court to consider A.T.’s motion to withdraw her plea in light of the opinion and lifted its stay, making the decision final for purposes of expediting proceedings.
Issues
| Issue | Plaintiff's Argument (A.T.) | Defendant's Argument (Prosecution/Court) | Held |
|---|---|---|---|
| Whether detention was used to coerce a plea | Detention (15–16 days) and repeated denials of release coerced A.T. into pleading guilty to obtain release | The court saw detention as justified by charges and denied release on safety grounds; prosecutor relied on package deal requirement | Held: Court detained A.T. to pressure plea; coercion violated due process and juvenile protections |
| Whether the court improperly considered neighborhood suitability | A.T.: court relied on subjective, categorical views of downtown Vallejo despite mother's uncontradicted testimony about safety | Court: cited familiarity with Vallejo and safety concerns to justify detention | Held: Court gave improper weight to its own view of neighborhood without evidentiary, individualized findings |
| Whether package-deal pleas with codefendants (siblings/minors) require special scrutiny | A.T.: package deal coerces minors, undermines individualized juvenile treatment and may prevent exculpatory testimony | Prosecution: offers plea as reasonable resolution; insisted on global resolution | Held: Package-deal offers pose special dangers, magnified for minors; pleas under such offers require heightened scrutiny |
| Whether juvenile court made required individualized, statutory findings for detention | A.T.: juvenile law requires evidence-based individualized detention findings and specification of statutory ground | Court: relied on offense seriousness and neighborhood risk without specifying supported statutory ground or hearing relevant evidence | Held: Court failed to make individualized, evidence-supported findings as required by sections 635/636 and controlling precedent |
Key Cases Cited
- In re William M., 3 Cal.3d 16 (court must favor release; individualized detention findings required)
- In re Ibarra, 34 Cal.3d 277 (package-deal pleas can coerce defendants; require special scrutiny)
- Alfredo A. v. Superior Court, 6 Cal.4th 1212 (detention decisions require consideration of personal/family factors and statutory presumptions in favor of release)
- People v. Sandoval, 140 Cal.App.4th 111 (totality-of-circumstances review of package-deal plea voluntariness)
- In re Lewallen, 23 Cal.3d 274 (punishing exercise of trial rights is a due process violation)