In Re Tyler D., 1 CA-JV 16-0311

In August 2014, Tyler pleaded delinquent to attempted molestation of a child and was placed on probation with sex‑offender treatment; registration was initially deferred.
Tyler later admitted violating probation by failing to actively participate in treatment; the court ordered detention for the violation.
About two weeks before Tyler turned 18, the court held a review on whether to impose sex‑offender registration through age 25 under A.R.S. § 13‑3821.
The court considered a psychosexual evaluation (which declined to opine on registration), Tyler’s incomplete progress in treatment, and the State’s recommendation to require registration because treatment was not completed.
Defense argued Tyler’s baseline risk was moderate and that delays in treatment resulted from anger/impulsivity and family interference; the State emphasized the lengthy delay (20 months) to complete a 9–12 month program.
The superior court ordered Tyler to register as a sex offender; Tyler appealed and counsel filed an Anders brief; the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court abused discretion in ordering juvenile sex‑offender registration	Tyler: no registration warranted given only moderate initial risk, treatment progress, and family interference causing delay	State: registration is appropriate because Tyler failed to complete required treatment and took 20 months to do half the program	Affirmed — court did not abuse discretion; considered evaluation and treatment history and permissibly ordered registration
Whether procedural or constitutional rights were violated during registration proceedings	Tyler: (implicitly) procedural fairness concerns due to treatment/interference issues	State: proceedings complied with juvenile procedure and Tyler had counsel and opportunity to be heard	Affirmed — record shows Tyler had counsel and constitutional/statutory rights were afforded

Anders v. California, 386 U.S. 738 (U.S. 1967) (procedures for counsel filing a brief asserting no non‑frivolous appeal)
State v. Leon, 104 Ariz. 297 (Ariz. 1969) (standard for appellate review when counsel files a no‑merit brief)
State v. Clark, 196 Ariz. 530 (App. 1999) (appellate review for reversible error)
In re Nickolas T., 223 Ariz. 403 (App. 2010) (juvenile sex‑offender registration under A.R.S. § 13‑3821 within court discretion)
State v. Shattuck, 140 Ariz. 582 (Ariz. 1984) (counsel’s post‑appeal obligations to inform client and identify review options)
Maricopa Cty. Juvenile Action No. JV‑117258, 163 Ariz. 484 (App. 1989) (procedures relating to Anders/Leon no‑merit filings)