In re J.G., 2026 Cal. LEXIS 525, (Cal. 2026)

The California Court of Appeals, First District held the courts imposition of an electronics search probation condition invalid, finding under the first and third prongs of the Lent test that the condition “1)has no relationship to the crime which the offender was convicted, and 3) requires or forbids conduct which is not reasonably related to future criminality.” People v. Lent (1975) 15 Cal.3d 481, 124 Cal. Rptr. 905, 541 P.2d 545.

The court reasoned in part: “A juvenile court is authorized to impose any reasonable conditions that it may determine “fitting and proper to the end that justice may be done and the reformation and rehabilitation of the ward enhanced.” (§ 730, subd. (b).) Notably, “[t]he permissible scope of discretion in formulating terms of juvenile probation is even greater than that allowed for adults,” given that “juveniles are deemed to be ‘more in need of guidance and supervision than adults’ ” and that the state “ ‘stands in the shoes of the parents . . . in caring for the minor’s well being’ ” when it asserts jurisdiction over the minor. (In re Victor L. (2010) 182 Cal.App.4th 902, 909–910.)

This broad discretion, however, is not unlimited. (In re J.B. (2015) 242 Cal.App.4th 749, 754.) A probation condition is invalid if it “ ‘(1) has no relationship to the crime of which the offender was convicted, (2) relates to conduct which is not in itself criminal, and (3) requires or forbids conduct which is not reasonably related to future criminality.’ ” (Lent, supra, 15 Cal.3d at p. 486.) The Lent test is “conjunctive—all three prongs must be satisfied before a reviewing court will invalidate a probation term.” (People v. Olguin (2008) 45 Cal.4th 375, 379.) As the Supreme Court has explained, a condition of probation that “requires or forbids conduct which is not itself criminal is valid if that conduct is reasonably related to the crime of which the defendant was convicted or to future criminality.” (Lent, at p. 486.) Wereview the imposition of a probation condition for an abuse of discretion (ibid.), taking into account “ ‘the sentencing court’s stated purpose in imposing it’ ” (In re P.O. (2016) 246 Cal.App.4th 288, 294).

J.G. contends all three prongs of the Lent test have been satisfied, while the People argue the first and third prongs have not been met. For the reasons below, we conclude the trial court abused its discretion in imposing the electronics search condition because, as framed, the condition is invalid under Lent.”