In re the Appeal in Maricopa County Juvenile Action No. J-86843

608 P.2d 804, 125 Ariz. 227, 1980 Ariz. App. LEXIS 385
CourtCourt of Appeals of Arizona
DecidedMarch 18, 1980
DocketNo. 1 CA-JUV 110
StatusPublished
Cited by7 cases

This text of 608 P.2d 804 (In re the Appeal in Maricopa County Juvenile Action No. J-86843) is published on Counsel Stack Legal Research, covering Court of Appeals of Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re the Appeal in Maricopa County Juvenile Action No. J-86843, 608 P.2d 804, 125 Ariz. 227, 1980 Ariz. App. LEXIS 385 (Ark. Ct. App. 1980).

Opinions

[228]*228OPINION

WREN, Judge.

Again this Court is faced with the contention that commitment of a juvenile to the Department of Corrections for a potentially longer period of time than an adult committing the same crime could be imprisoned is a denial of equal protection of the law, under the theory espoused in People v. Olivas, 17 Cal.3d 236, 131 Cal.Rptr. 55, 551 P.2d 375 (1976).

The question has now been answered by the Arizona Supreme Court In the Matter of the Appeal in Maricopa County Juvenile No. J-86509, 124 Ariz. 377, 604 P.2d 641 (1979) vacating 124 Ariz. 380, 604 P.2d 644 (App.1979). In its opinion, the state High Court, as had the Court of Appeals, expressly rejected the juvenile’s contention that sentencing disparity between adult and juvenile courts violated equal protection guarantees, and specifically ruled that a juvenile could suffer a loss of liberty for a longer period than an adult imprisoned for conviction of the same offense. However, the Supreme Court went on to strike down A.R.S. § 8-246 providing for retention of jurisdiction and power by the Department of Corrections and juvenile court beyond age 18 as unconstitutional.1

In the case now before us the crime is a class 6 felony (theft of a motor vehicle valued less than $100.00) for which the maximum sentence is 1.875 years, and the juvenile, 16 years of age, faces a possible commitment of over four years; more than twice the period of time an adult could receive. We are asked by the juvenile appellant to direct that the commitment order of the juvenile court be terminated upon a date not in excess of 1.875 years.

Since the issue has been disposed of by the Arizona Supreme Court, there is little to say in disposing of this case. Nevertheless we feel quite strongly that we are reaching a point where overzealous applications of equal protection principles threaten to frustrate the special purposes of juvenile court law and we would like to vent our thoughts.

The Supreme Court has determined that Article 6, § 152 fails to afford any special protection to persons eighteen years of age or older, and that, absent special constitutional protection, there is no legal justification for extending the juvenile court’s jurisdiction (special protection) to persons between the ages of 18 and 21 because there is no legitimate reason for classifying adults between those ages any differently than adults 21 years of age or older.

In doing so, the Arizona Supreme Court has blazed a new trail that all other jurisdictions considering a similar question have refused to follow.3 The real problem, as [229]*229the court apparently saw it, was the fact that A.R.S. § 8-201(3) defined “adult” as a person 18 years of age or over, while A.R.S. § 8-202(D) and § 8-246 sought to continue the power of juvenile court beyond a person’s eighteenth birthday:

We submit that the last sentence of Article 6, § 15 means that once the juvenile court has acquired proper jurisdiction over persons under the age of 18, it may continue control over these persons as provided by law; which means as provided by the legislature. This decision, in our opinion, casts a long shadow over the recognized right of the legislature to fix and change the age of majority. Previous Arizona decisions that have touched on the scope of Article 6, § 15 impliedly found no fault with the juvenile court’s continuing control as long as the juvenile court properly acquired jurisdiction in the first instance. See McBeth v. Rose, 111 Ariz. 399, 531 P.2d 156 (1975). Cf. also Hoover v. Department of Corrections, 109 Ariz. 485, 512 P.2d 594 (1973). This Court has heretofore expressly stated that:

“. . the clear import of the legislative enactments in Title 8 dealing with the extension of jurisdiction over a juvenile beyond his [18th] birthday up to the age of [21] unless sooner terminated by law or order of the court is that the juvenile still remains under the jurisdiction of the juvenile court and is subject to and protected by the same considerations as though he were under eighteen.” In the Matter of the Appeal in Maricopa County Juvenile Action No. J-85871, 120 Ariz. 154, 156, 584 P.2d 618, 620 (App. 1978).

In 1972, when the legislature lowered the age of majority from 21 to 18, and redefined adult under A.R.S. § 8-201(3) as a person 18 years of age or older, and a child under A.R.S. § 8-201(5) as an individual who is under the age of eighteen years, (Laws 1972, Ch. 146, § 10), A.R.S. §§ 8-202 and 8-246 were left unscathed. Then, in 1973 the legislature amended A.R.S. § 8-246 by substituting the words “such child” for the word “he” preceding the words “becomes 21 years of age” in subsection A, and substituted the words “ ‘twenty-first birthday’ and ‘age of twenty-one years’ ” for the word “majority” in subsection B. (Laws 1973, Ch. 162, § 1). No other changes were made.

History tells us, and courts have unanimously approved the proposition, that the legislature may prescribe longer periods of minority for some purposes than for others. Chatwin v. Terry. As pointed out by our State Supreme Court in Stanley v. Stanley, 112 Ariz. 282, 541 P.2d 382 (1975): “We have held that majority or minority is a status rather than a fixed or vested right and that the legislature has full power to fix and change the age of majority.” (citations omitted.)4

Obviously, the Arizona legislature had concluded that children as a class should be subject to indefinite periods of confinement not to extend beyond their 21st birthday, in order to insure sufficient time to accord the child sufficient treatment of the type required for his effective rehabilitation.5 The [230]*230statute was designed to impart to the juvenile court system the flexibility needed to deal with youthful offenders.

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Bluebook (online)
608 P.2d 804, 125 Ariz. 227, 1980 Ariz. App. LEXIS 385, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-the-appeal-in-maricopa-county-juvenile-action-no-j-86843-arizctapp-1980.