In the Interest of D.S., 37 A.3d 1202

D.S., a minor, was adjudicated delinquent on December 1, 2009 for theft by unlawful taking and placed on indefinite probation.
On May 27, 2010, the court held a probation-violation dispositional hearing addressing alleged violations, including extensive school absences and curfew breaches.
The court ordered a disposition placing D.S. at St. Michael’s Diagnostic Program for comprehensive evaluation of mental health, drug, educational, and behavioral needs, based on the alleged needs and proximity to home.
D.S.’s mother opposed the St. Michael’s placement, favoring Camp Adams and raising concerns about outcomes and safety of other children in the home.
The May 27, 2010 proceeding purportedly resulted in a dispositional order transferring D.S. to St. Michael’s, with detention pending transfer, though the record later showed charting deficiencies and lack of a formal, filed dispositional order.
The majority affirmed the trial court’s disposition, citing broad discretionary authority under the Juvenile Act and emphasizing rehabilitation and least-restrictive placement considerations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was St. Michael’s the least restrictive placement addressing D.S.’s needs?	D.S. argued that a less restrictive option would better meet his mental health and rehabilitation needs.	The court appropriately weighed treatment, supervision, rehabilitation, and welfare, selecting a placement close to home that addresses needs.	Dispositional placement affirmed; no manifest abuse of discretion.
Did the court provide due process and allow input on placement alternatives?	Mother should have been afforded opportunity to suggest alternatives (e.g., Camp Adams) and to receive adequate information.	Court heard evidence and weighed input, including the mother’s concerns, within the scope of its discretion.	No reversible due process violation; record supports the chosen disposition.
Did the record properly comply with Rules of Juvenile Court Procedure (512, 515, 612) and reflect a proper dispositional order?	Record deficiencies and lack of proper motions/docket entries undermine the dispositional order.	Court's memorandum and proceedings sufficiently support disposition under the Juvenile Act; any technical record issues were not reversible.	Dispositional order affirmed despite record-keeping concerns.

In re L.A., 853 A.2d 388 (Pa. Super. 2004) (abuse of discretion standard in juvenile dispositions)
In re Love, 646 A.2d 1233 (Pa. Super. 1994) (deference to trial court dispositions; manifest abuse standard)
In the Interest of A.D., 771 A.2d 53 (Pa. Super. 2001) (Legislative intent to protect community while rehabilitating juveniles)
The Interest of J.C., 751 A.2d 1181 (Pa. Super. 2000) (community protection and rehabilitation balance in juvenile dispositional review)
Commonwealth v. Zurburg, 937 A.2d 1131 (Pa. Super. 2007) (abuse of discretion standard; not merely error in judgment)