In Re Brent F.

Brent F. (the minor) committed a sexual battery and was declared a ward of the juvenile court. His placements in various group homes failed because of the “extreme risk” that he would “sexually victimize others” in the group homes. Other group homes refused to take the minor because of his “sexual aggressiveness” and lack of amenability to therapy. Ultimately, the minor was placed in a sexual offender treatment program. However, this placement also failed because the minor was “unwilling or unable to control his deviant behavior” and he had a propensity to run away, thus posing a danger to the community.

Consequently, the probation department filed a Welfare and Institutions Code section 778 supplemental petition, seeking to commit the minor to the California Youth Authority (CYA) because the probation officer had “exhausted all [other] placement options ...” (Further section references are to the Welfare and Institutions Code unless otherwise specified.) Over the minor’s objection that a section 778 petition cannot be used to obtain the disposition sought by the probation department, the juvenile court sustained the supplemental petition and committed the minor to…