Sebastian C., now 19, was committed to a secure youth treatment facility at age 14 after admitting to voluntary manslaughter. With approximately nine months left on his baseline term in January 2025, the Solano County probation department petitioned to place him in his adult sister's home as part of a "less restrictive program" that would include weekly probation contacts, therapy referrals, and other community-based services.
The Solano County Superior Court denied the placement request. Judge Terrye Davis explained that the law "very clearly states here that the less restrictive program is supposed to be providing the community transition services" and concluded "I do not believe his sister's house is a program."
Writing for a unanimous three-judge panel, Justice Goldman rejected the trial court's narrow interpretation of state law, holding that "placement in a family home with supervision and programming provided by a community-based agency can meet the requirements of a less restrictive program under section 875, subdivision (f)."
"We are not persuaded by this reading of the statute," Goldman wrote, criticizing the lower court's determination that the sister's home wasn't a "program." The appeals court noted that the law identifies "community nonresidential service program" as an example of a less restrictive placement, and that "a ward could receive programming or services from a community nonresidential service program while being housed in a relative's home."
The Court of Appeal dismissed the case as moot because Sebastian had since been placed in a less restrictive program with his mother. However, Justice Goldman wrote that the court exercised discretion to address the legal issue because "interpretation of section 875, subdivision (f) is a matter of public importance and clarification on the definition of a less restrictive program under that provision would be helpful both to trial courts in general."
The court cited guidance from the state's Offices of Youth and Community Restoration emphasizing that "whenever possible, home with robust supports as detailed in youths' [individualized rehabilitation plans] should be utilized as less restrictive programs." Justice Goldman noted this recommendation was "consistent with both the language and purpose of the statute" when combined with community-based programming and supervision.
Sebastian had previously been placed at the county's Rise Up House less restrictive program in March 2025, but was returned to the secure facility in May 2025 for alleged non-compliance before his final placement with his mother in February 2026.