In re R.A. CA3

── In re R.A. CA3 ── Court: California Court of Appeal Date: April 20, 2026 Category: General Filed 4/20/26 In re R.A. CA3 NOT TO BE PUBLISHED California Rules of Court, rule 8.1115(a), prohibits courts and parties from citing or relying on opinions not certified for publication or ordered published, except as specified by rule 8.1115(b). This opinion has not been certified for publication or ordered published for purposes of rule 8.1115. IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA THIRD APPELLATE DISTRICT (San Joaquin) In re R.A., a Person Coming Under the Juvenile Court C103231 Law. (Super. Ct. No. JJC-JV-DE- THE PEOPLE, 2022-0001402) Plaintiff and Respondent, v. R.A., Defendant and Appellant. Upon determining that R.A. violated probation by using marijuana, the juvenile court committed R.A. to juvenile hall for 540 days, a sentence that the court had initially stayed in favor of home detention on probation with GPS monitoring. On appeal, R.A. argues that the juvenile court abused its discretion: (1) in “automatically” lifting the stay and imposing the commitment without a reassessment of R.A.’s circumstances; and (2) in imposing a 540-day commitment in this case. The People concede this court should remand the matter to the juvenile court. In light of this concession, the People argue that R.A.’s second contention on appeal is moot or not ripe. R.A. on reply agrees that, if this case is remanded, his contention that his commitment was an abuse of discretion is moot. We agree with the parties that the juvenile court erred in imposing the 540-day commitment without considering relevant factors and will vacate the disposition order 1 and remand for the court to conduct a new disposition hearing. Therefore, we do not reach R.A.’s contention that a 540-day commitment itself was an abuse of discretion. BACKGROUND1 In December 2022, a juvenile wardship petition filed under Welfare and Institutions Code section 602 charged 15-year-old R.A. with misdemeanor battery (Pen. Code, § 242). In January 2023, a second petition charged R.A. with the same crime against a different victim. In March 2023, R.A. admitted the charge in the first petition and the second petition was dismissed. The juvenile court placed R.A. on six months’ informal probation under Welfare and Institutions Code section 725. In August 2023, a petition charged R.A. with two counts of felony vandalism (Pen. Code, § 594, subd. (a)(1); counts 1 & 2) and alleged as enhancements to both counts that R.A. committed the offenses for the benefit of a criminal street gang (id., § 186.22, subd. (b)(1)). As a separate count, the petition charged R.A. with the substantive offense of participation in a criminal street gang (id., § 186.22, subd. (a); count 3.) At a hearing in August 2023, the juvenile court terminated informal probation. The court ordered R.A. to remain released to his father with conditions. In September 2023, a petition charged R.A. with second degree burglary (Pen. Code, § 459; count 1), grand theft (id., § 487, subd. (a); count 2), two counts of receiving stolen property (id., § 496, subd. (a); counts 3 & 5), and misdemeanor vandalism (id., § 594, subd. (b)(2)(A); count 4). In October 2023, a second wardship petition charged R.A. with two counts of felony vandalism to two vehicles (id., § 594, subd. (b)(1); counts 1 & 2). The petition was later amended to add two counts of burglary of the same vehicles (id., § 459; counts 3 & 4). A second amendment added felony vandalism and 1 We do not recount the underlying facts that are not relevant to the issues on appeal