In re M.A.

I. BACKGROUND

The juvenile court assumed jurisdiction over M.A. upon his admission that he had committed a felony sexual battery (§ 243.4).2 At the disposition hearing, by agreement of the parties, the juvenile court adjudged M.A. a ward of the juvenile court and granted him probation for one year. At the recommendation of the probation officer—who noted that sexual battery was among the offenses referenced in section 29805—and over defense counsel’s objection, the court ordered “[t]hat [M.A.] shall immediately surrender any and all firearms in his . . . possession, custody and control and refrain from possessing, owning, or controlling any and all firearms until his . . . 30th birthday.”

II. DISCUSSION

M.A. argues that the firearms prohibition is not legally authorized under either section 29805 or section 29820 for his commission of a felony sexual battery, and that the juvenile court therefore abused its discretion in ordering it. In M.A.’s view, he is categorically exempt from the ban because section 29805 applies only to adult criminal misdemeanants3 and section 29820 therefore permits a firearms restriction for juveniles only where the court declares the violation…