Commitment of minor to a Secure Youth Treatment Facility (SYTF) was error under the “most recent offense” rule where his sole qualifying offense was not the most recent misdeed. Minor admitted to offenses in three wardship petitions where the conduct occurred in March, June, and December, 2024. Minor was committed to a SYTF based on the sole WIC 707(b) offense, committed in June 2024. Reversal was required as the “most recent offense” rule requires that a juvenile’s commitment to a SYTF be based on the most recent offense for which the juvenile has been adjudicated. “Most recent” refers to when the juvenile committed the offense, not when the petition was adjudicated. [Editor’s Note: A.P.J. Yegan concurred, asking the Legislature to revisit the statute due to an absurd result and miscarriage of justice.]

The full opinion is available on the court’s website here: https://www4.courts.ca.gov/opinions/documents/B342991.PDF