People v. Alonzo, 58 Cal. 4th 924

13-year-old Alonzo J. faced three charges (two felonies, one misdemeanor) in juvenile court after alleged assaults and vandalism; he faced a plea offer: admit one felony to return home on probation, or admit only misdemeanor to placement; his attorney refused to consent to an admission and opposed a no contest plea; Marsden motion indicated attorney believed he was factually innocent of the felonies; the court would not accept a plea without counsel consent and instead pursued a contested jurisdictional hearing; the Court of Appeal reversed, concluding no contest plea required only court approval, not counsel consent; the California Supreme Court held counsel consent is required for no contest pleas as for admissions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel consent is required for a no contest plea in a delinquency proceeding	Alonzo argues no contest should be allowed without counsel consent	No contest should be allowed with court approval only	Yes, counsel consent required for no contest plea
whether rule 5.778 permits no contest pleas without counsel consent	Rule 5.778(e) allows no contest with court approval only	No contest should require counsel consent as to admissions	No contest plea requires counsel consent (as admissions do)
Whether a no contest plea in delinquency proceedings has the same effect as an admission	No contest should be treated differently from admission	No contest should have a separate effect	No contest has the same effect as admission; both require consent and lead to disposition
Constitutionality of requiring counsel consent for no contest pleas	Counsel consent may burden rights to participate in plea	Consent requirement protects minor’s rights	Constitutionality upheld only with counsel consent (consistent with statute)

In re Alvernaz, 2 Cal.4th 924 (1992) (right to participate in defense decisions includes plea decisions)
People v. Alfaro, 41 Cal.4th 1277 (2007) (counsel-consent requirement for guilty pleas in capital cases upheld)
People v. Snyder, 208 Cal.App.3d 1141 (1989) (not absolute right to have plea accepted over counsel)
In re Robin M., 21 Cal.3d 337 (1978) (rights of the minor in admissions/no contest context)
Coalition of Concerned Communities, Inc. v. City of Los Angeles, 34 Cal.4th 733 (2004) (statutory interpretation and balancing public policy)
Alan v. American Honda Motor Co., 40 Cal.4th 894 (2007) (statutory construction and rule consistency with statute)
Silverbrand v. County of Los Angeles, 46 Cal.4th 106 (2009) (statutory interpretation - drafting intent)