County of Los Angeles v. RALPH V.

Ralph and Alice V. appeal from judgments requiring them to pay the County of Los Angeles (county) a total of $20,154 as reimbursement for support of their minor son while confined as a ward of the juvenile court under Welfare and Institutions Code section 602. Appellants principally contend that the judgments were improperly imposed, because the trial court did not require the county to itemize and prove the particular components of support it sought to recover. We conclude that the procedure employed complied with constitutional limitations on governmental assessment of support from the parents of juvenile court wards. Although we therefore affirm the judgments, we also direct further proceedings to ensure that the funds recovered under the judgments will be disposed of in accordance with statutory and constitutional requirements.

Statement

In 1991 appellants’ 14-year-old son was found to have committed a battery upon Alice V., and was declared a ward of the juvenile court under section 602. The court ordered him removed from appellants’ custody and “suitably placed.” Except for one and one-half months during which he ran away, the minor was confined in either juvenile…