Unreported / Non-Citable
Background
In June 2024, the Santa Clara County District Attorney filed a juvenile wardship petition under Welfare and Institutions Code section 602, alleging that A.T. had committed sexual battery against P.B. A.T. requested deferred entry of judgment (DEJ), which allows a minor to admit the allegations and have charges dismissed upon successful completion of a program. Although statutorily eligible under section 790, the People opposed DEJ, arguing A.T. was unsuitable under section 791, subdivision (b), citing a pattern of sexually inappropriate behavior dating to 2018, including unwanted touching of multiple students. The probation department initially found A.T. suitable based on his maturity and family relationships, but after the district attorney amended the petition to add a second count against L.C., the juvenile court held a November 2024 suitability hearing.
The court denied DEJ, reasoning that the alleged offenses reflected A.T.'s immaturity and the inability of his family relationships—though strong—to prevent subsequent allegations. The court also noted the predatory nature of the offenses and the vulnerability of the victims. In July 2025, the district attorney filed a third amended petition alleging two counts of sexual battery (count 1 against P.B. between September 2021 and June 2022; count 2 against L.C. between January 2022 and June 2023) and one count of sexual penetration of a person under 18 (count 3 against L.C.). Following a contested jurisdictional hearing, the juvenile court found the allegations true beyond a reasonable doubt—count 1 as a misdemeanor and counts 2 and 3 as felonies—declared A.T. a ward of the court, and placed him on probation for a maximum term of three years eight months.
The Court’s Holding
The Court of Appeal affirmed the denial of DEJ, holding that the juvenile court did not abuse its discretion in determining A.T. was unsuitable. The appellate court found that the juvenile court properly considered the statutory factors under Welfare and Institutions Code section 791, subdivision (b), including A.T.'s maturity and family relationships. The court reasonably concluded that A.T.'s pattern of sexually aggressive behavior over several years, despite interventions by school authorities, demonstrated immaturity. The appellate court also upheld the finding that A.T.'s mother had not responded appropriately to prior warnings, noting she appeared unconcerned when informed of his misconduct. The court explained that DEJ is a lower sanction than formal probation with different consequences for violations, so the denial did not hinge solely on the level of supervision.
The Court of Appeal also held that sufficient evidence supported the felony sexual battery conviction for count 2. The court found substantial evidence that A.T. unlawfully restrained L.C. in a gender-neutral restroom by locking the door, dragging her into a stall, locking the stall door, and pressing his arm against her back with strong pressure. L.C. testified that she felt scared, frozen, and unable to leave. The court explained that unlawful restraint does not require physical restraint and can be established through words, acts, or authority that deprive a person of liberty against their will. The court distinguished People v. Arnold, where the victim voluntarily accompanied the defendant, noting that here A.T.'s later actions inside the restroom caused L.C.'s fear and restraint.
Key Takeaways
- A juvenile court has broad discretion to deny deferred entry of judgment based on a minor's pattern of behavior and the circumstances of the charged offenses, even if the probation department finds the minor suitable.
- Evidence that a minor continued inappropriate behavior despite prior interventions supports a finding of immaturity and unsuitability for DEJ.
- A parent's inadequate response to warnings about a minor's behavior can support a finding that family relationships do not weigh in favor of DEJ suitability.
- Unlawful restraint for felony sexual battery under Penal Code section 243.4, subdivision (a), does not require physical restraint and can be established through psychological pressure and circumstances that deprive the victim of liberty.
- Locking doors, physically preventing a victim from leaving, and creating a situation where the victim feels frozen in fear can constitute unlawful restraint.
Why It Matters
This case illustrates the broad discretion juvenile courts have in determining suitability for deferred entry of judgment and the substantial deference appellate courts give to those determinations. Even when a probation department recommends DEJ and the minor has recent incident-free months, a juvenile court may deny DEJ based on the totality of the circumstances, including the minor's history of behavior and the family's response to prior warnings. The decision also clarifies that unlawful restraint for felony sexual battery can be established through a combination of physical and psychological pressure, and that locking doors and creating a situation where the victim feels unable to leave can suffice, even if the victim does not physically resist or attempt to escape.