In re A.N., 462 P.3d 974

A.N., a ninth‑grade student, accumulated numerous unexcused absences/tardies; school principal sent multiple truancy letters and a police officer issued a habitual‑truancy citation before the juvenile petition was filed.
The Ventura County District Attorney filed a wardship petition under Welfare & Institutions Code § 601, alleging A.N. was a habitual truant based on "four or more truancies" in one school year.
A SARB meeting occurred after the petition was filed; A.N. and her mother signed a contract at that meeting.
At trial the attendance supervisor testified a computerized system automatically sends attendance reports to the district; the record supported that at least four truancy reports had been sent before the petition.
The juvenile court sustained the wardship petition; the Court of Appeal affirmed; the California Supreme Court granted review to decide whether SARB referral or issuance of a fourth truancy report are prerequisites to formal juvenile‑court jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether referral to a SARB or similar truancy mediation program is a prerequisite to juvenile‑court jurisdiction under Welf. & Inst. Code § 601(b)	People: Not required; §601(b) includes "four or more truancies" as independent basis for jurisdiction after statutory amendments	A.N.: SARB referral (per Education Code §48264.5(c)) remains a condition precedent; legislative history and purpose show court intervention should be last resort	Court: SARB referral is discretionary, not a prerequisite; §601(b) independently grants jurisdiction on four or more reported truancies
Whether a fourth "truancy report" must be issued, and to whom, before court may adjudicate under §601(b)	People: "Truancies" refer to reports sent to attendance supervisor/superintendent under §§48260–48261; parental notice (§48260.5) is distinct	A.N.: §48264.5(d) requires a fourth truancy report be issued to the pupil and parents/guardians before court jurisdiction	Court: A fourth truancy report must be issued to the attendance supervisor or superintendent (internal report) under §§48260–48261; parental notification obligations remain governed by other statutes but are not the report that triggers §601(b) jurisdiction

In re Michael G., 44 Cal.3d 283 (Cal. 1988) (discussed prior dictum that SARB referral was a condition precedent to court intervention)
In re James D., 43 Cal.3d 903 (Cal. 1987) (background on SARBs and diversionary purpose prior to 1994 amendments)
Lexin v. Superior Court, 47 Cal.4th 1050 (Cal. 2010) (statutory construction principle to read related provisions in pari materia)
In re R.T., 3 Cal.5th 622 (Cal. 2017) (statutory‑interpretation starting point: text is primary evidence of legislative intent)
In re Richard E., 21 Cal.3d 349 (Cal. 1978) (‘‘may’’ ordinarily grants discretion)
People v. Gray, 58 Cal.4th 901 (Cal. 2014) (presumption that identical terms used in statute bear the same meaning)