In Re Eddie M.

At the March 7, 2000, Primary Election, California voters approved Proposition 21, the Gang Violence and Juvenile Crime Prevention Act of 1998 (Proposition 21). Proposition 21 operated, among other things, to amend juvenile court procedures, including Welfare and Institutions Code section 777. As configured since 1986, section 777 allowed a more restrictive disposition for a person who, while already on juvenile probation for a criminal offense adjudicated under section 602, violated that probation by committing new misconduct.

As pertinent here, Proposition 21 revised section 777 in two respects. First, before Proposition 21, the prosecutor could “allege[ ] a violation of a condition of probation amounting to a crime,” and either the probation officer or the prosecutor could “allege[ ] a violation of a condition of probation not amounting to a crime.” (§ 777, former subd. (a)(2), as amended by Stats. 1986, ch. 757, § 5, p. 2478, italics added (former section 777(a)(2)).) Proposition 21 deleted the initial nonitalicized phrase from section 777, subdivision (a)(2) (section 777(a)(2)).

Second, before Proposition 21, the reasonable doubt standard governed all section…