In Re Ruben P., 1 CA-JV 21-0018

Ruben P., first juvenile contact with police just before age 14; over ~26 months he had multiple law-enforcement contacts, numerous referrals, and several detentions (including cutting off an electronic monitor and being on warrant status).
He pleaded delinquent to four felonies (firearm possession; solicitation to commit third-degree burglary; two thefts) with the disposition hearing in January 2021.
A psychologist diagnosed him with conduct and other disorders, opining he could not be trusted in the community and recommending intensive behavioral placement.
Juvenile Probation Officer and the State recommended commitment to ADJC (citing running away, gang involvement, substance use, refusal of counseling, and security concerns); defense and guardian ad litem sought placement at Sycamore Canyon (a residential treatment center).
The superior court committed Ruben to the Arizona Department of Juvenile Corrections (ADJC), citing referral history, poor performance on release, the nature of the felony adjudications, and the need for a secure setting; the court initially misstated the felony-warning language but the record shows correction before disposition.

Issue	Plaintiff's Argument (Ruben)	Defendant's Argument (State)	Held
Whether the court's misstatements (reading a repeat-felony warning) show the court relied on inaccurate information and thus abused its discretion	The repeated misstatements indicate the court relied on incorrect/relevant sentencing framework, infecting the disposition	The misstatements were corrected, were unimportant to the court's reasoning, and did not affect the disposition	No abuse of discretion; misstatements did not affect disposition and were corrected
Whether the court failed to consider commitment guidelines and less restrictive alternatives before committing to ADJC	The court did not follow/consider guideline factors fully or attempt less restrictive secure treatment before choosing ADJC	The court considered the guidelines and was aware Sycamore Canyon was available but reasonably concluded ADJC (a secure facility) was appropriate	No abuse of discretion; court complied with guidelines and reasonably rejected the less restrictive alternative

In re Miguel R., 204 Ariz. 328 (App. 2003) (standard: appellate review for abuse of discretion in juvenile dispositions)
In re John M., 201 Ariz. 424 (App. 2001) (same standard and deference to trial court factfinding)
In re Harry B., 193 Ariz. 156 (App. 1998) (misstatements that are immaterial to the disposition do not require reversal)
In re Melissa K., 197 Ariz. 491 (App. 2000) (court reversed where commitment contradicted applicable guidelines and less-restrictive options were not shown to have been considered)
In re Niky R., 203 Ariz. 387 (App. 2002) (commitment guidelines do not unduly restrict juvenile court’s discretion)
State v. Lee, 189 Ariz. 608 (1997) (presumption that judges know and apply the law)