People v. D.B., 58 Cal. 4th 941

Case involves a Welfare and Institutions Code section 602 petition alleging multiple offenses by a minor (D.B.).
Question presented: whether DJF commitment is allowed if the last offense in the petition is nonviolent.
Lower court (Court of Appeal) held DJF eligibility requires the most recent offense be listed in section 707(b) or §290.008(c).
Supreme Court agrees that DJF eligibility hinges on the most recent offense adjudicated, not any prior offenses in the petition.
D.B. committed a 2010 sequence including violent and nonviolent offenses; one count (robbery) is violent/serious; others include nonviolent offenses.
Court affirms Court of Appeal’s interpretation that the last adjudicated offense must be listed in §707(b) or §290.008(c) to authorize DJF.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DJF eligibility turns on the most recent offense only.	People: any qualifying offense among the most recent petition suffices.	D.B.: eligibility should be based on the last adjudicated offense.	DJF eligibility rests on the most recent offense adjudicated, must be listed in §707(b) or §290.008(c).

Greg F. v. Superior Court, 55 Cal.4th 393 (Cal. 2012) (realignment context; anticipated problem with most recent offense rule)
In re J. W., 29 Cal.4th 200 (Cal. 2002) (absurd consequences not allowed; interpret statute pragmatically)
People v. Mendoza, 23 Cal.4th 896 (Cal. 2000) (statutory interpretation against absurd results)
Cassel v. Superior Court, 51 Cal.4th 113 (Cal. 2011) (needs for overriding literal meaning require extreme reasonableness)
In re N.D., 167 Cal.App.4th 885 (Cal. App. 2008) (realignment and DJF placement policy context)
V.C. v. Superior Court, 173 Cal.App.4th 1455 (Cal. App. 2009) (multicount petition implications for DJF)
Murphy v. Kenneth Cole Productions, Inc., 40 Cal.4th 1094 (Cal. 2007) (interpretation when language clear; avoid absurd outcomes)
People v. Weidert, 39 Cal.3d 836 (Cal. 1985) (principle of following plain meaning when unambiguous)