In re J.C.

CourtCalifornia Court of Appeal
DecidedFebruary 9, 2026
DocketA171619
StatusPublished

This text of In re J.C. (In re J.C.) is published on Counsel Stack Legal Research, covering California Court of Appeal primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re J.C., (Cal. Ct. App. 2026).

Opinion

Filed 2/6/26 CERTIFIED FOR PARTIAL PUBLICATION *

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION THREE

In re J.C., a Person Coming Under the Juvenile Court Law. THE PEOPLE, Plaintiff and Respondent, v. A171619 J.C., (Contra Costa County Defendant and Appellant. Super. Ct. No. J2400133)

J.C. was adjudged a ward of the juvenile court after pleading no contest to one felony count of attempted grand theft from the person (Pen. Code, §§ 664/487, subd. (c)) 1 and one misdemeanor count of brandishing an imitation firearm in a threatening manner (§ 417.4). He was placed on home supervision with various probation conditions, including a prohibition against owning and possessing a firearm until the age of 30. (§ 29820, subd. (b).) J.C. raises three claims of error on appeal. First, he contends the juvenile court exceeded its authority in imposing the firearm ban because the offense of brandishing an imitation firearm is not among the statutorily

* Pursuant to California Rules of Court, rules 8.1105(b) and 8.1110, this opinion is certified for publication with the exception of parts B and C of the Discussion. 1 Further unspecified statutory references are to the Penal Code.

1 enumerated offenses that trigger the ban. Second, he maintains a remand is necessary for the court to make a finding pursuant to In re Manzy W. (1997) 14 Cal.4th 1199 (Manzy W.) as to whether his “wobbler” offense of attempted grand theft from the person was a felony or misdemeanor. Finally, J.C. contends the punishment for one of his two offenses should have been stayed because both were based on a single act. In the published portion of this opinion, we conclude the firearm ban must be vacated, as the plain language and the legislative history of the governing statutes do not contemplate that an offense under section 417.4 triggers the ban. (See §§ 29805, 29820.) In the unpublished portion of our opinion, we conclude a remand is necessary for the juvenile court to make a Manzy W. determination as to J.C.’s wobbler offense. Accordingly, we will reverse the judgment and remand for further proceedings consistent with this opinion. FACTUAL AND PROCEDURAL BACKGROUND All dates are from 2024 unless specified otherwise. On the evening of March 12, Antioch police officers responded to a report of someone breaking into vehicles. While the officers were en route, the dispatcher advised them that another caller had reported the same person pulling out a firearm and asking her for money at an ATM machine. When the officers arrived at the scene, they observed J.C., who matched the description of the suspect, running through a parking lot and jumping into bushes. A “replica” firearm was found in the bushes. The victim told the officers that J.C. had approached her at the ATM machine and asked “ ‘[H]ow much money did you pull out?’ ” He then displayed what appeared to be a gun, and the victim ran to her car and drove away.

2 On March 14, a wardship petition under Welfare and Institutions Code section 602 was filed alleging that J.C., age 16, committed second degree robbery (§ 211; count one) and used a deadly and dangerous weapon (a “Replica 1911 .45 caliber handgun”) in the commission of the offense (§ 12022, subd. (b)(1)). The petition was later amended to allege that J.C. committed attempted second degree robbery (§§ 664, 211, 212.5, subd. (a)). At the jurisdiction hearing on April 4, the juvenile court granted the prosecutor’s request to amend the petition to substitute and add counts for felony attempted grand theft from the person (§§ 664, 487, subd. (c); count two) and misdemeanor brandishing an imitation firearm (§ 417.4; count three). 2 After the court advised J.C. of his trial rights and the maximum term of confinement, J.C. pled no contest to counts two and three. The court sustained the charges on those counts and dismissed count one and the related enhancement. The court then denied J.C.’s request for home supervision and ordered his detention in juvenile hall. At the initial disposition hearing on April 18, the juvenile court declared wardship and placed J.C. on home supervision in the custody of his parent or guardian for 90 days, with various probation conditions. Among them, condition number 31 required J.C. to submit DNA samples pursuant to section 296.1 because, as the court explained, “a felony count was sustained.”

2 Section 417.4 states: “Every person who, except in self-defense, draws or exhibits an imitation firearm . . . in a threatening manner against another in such a way as to cause a reasonable person apprehension or fear of bodily harm is guilty of a misdemeanor punishable by imprisonment in a county jail for a term of not less than 30 days.” “ ‘[I]mitation firearm’ ” is defined in relevant part as “any BB device, toy gun, replica of a firearm, or other device that is so substantially similar in coloration and overall appearance to an existing firearm as to lead a reasonable person to perceive that the device is a firearm.” (§ 16700, subd. (a)(1).)

3 However, the court reserved ruling on condition number 30, which prohibited J.C. from owning and possessing a firearm until the age of 30. The court set a hearing on the gun ban condition for May 16. At the continued hearing on May 16, the juvenile court maintained J.C. on home supervision and set a further hearing on “Home Supervision Review and Gun Ban” for June 11. The defense filed a brief arguing the firearm ban of section 29820, subdivision (b), did not apply to the offense of brandishing an imitation firearm under section 417.4. At the continued hearing on June 11, the juvenile court terminated home supervision but retained J.C. on electronic monitoring and set a hearing on “Gun Ban Applicability” for August 8. On July 25, the probation department filed a notice of probation violation (Welf. & Inst. Code, § 777) alleging J.C. failed to abide by his curfew and had a positive drug test. On August 8, the juvenile court held a combined hearing on the probation violation notice and the “outstanding” firearm ban question. After being advised that J.C. was prepared to admit the probation violation, the court advised J.C. of his rights to a probation violation hearing. The court then stated, “There is still a remaining period of time that you could be confined in a locked facility, [J.C.], and I believe that the maximum period of time has been one year, 60 days.” The court noted that J.C. had spent “a little bit” of time in juvenile hall and believed “there was one year and 23 days remaining, and I don’t think you spent any more time in Juvenile Hall since then. So that’s what I believe is the maximum period. [¶] I do understand that there’s a period of time that still exists and remains where you could be confined in a locked facility, and that would be for one year and 23 days. [¶] I need you to answer out loud.” J.C. responded, “Yes, ma’am.”

4 The juvenile court found that the allegation of J.C.’s probation violation was true and that he had made a knowing and intelligent waiver of his right to a contested probation violation hearing. The court placed J.C. on home supervision for 45 days. The juvenile court then found the firearm ban applied notwithstanding the absence of section 417.4 from the list of enumerated offenses in section 29805, subdivision (a)(1). In the court’s view, imposing the firearm ban for a section 417.4 offense was consistent with the Legislature’s concerns that an imitation firearm still poses a threat of harm to the wielder and others due to how it could be perceived by law enforcement. In the court’s words, the legislative intent “has [not] changed any—even with the change from 417.2 and the new 417.4. So I do believe the gun ban is applicable, that it is consistent with the legislative intent, and I’m imposing the gun ban, which I believe was initially in the probation terms.

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In re J.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-jc-calctapp-2026.