L.A.M. v. State
Supreme Court of Alaska
547 P.2d 827 (1976)
L.A.M. began running away from home at 14 and cycled through a series of escalating interventions - detention pending a child-in-need-of-supervision adjudication, release to her parents, another runaway episode, and eventually placement in a foster home with court-ordered counseling alongside her mother, with an explicit warning she would be incarcerated if she left the foster home without notifying her psychiatrist, mother, or social worker. Two months later she ran away from the foster home without telling anyone, was apprehended and charged with criminal contempt, and while awaiting trial ran away from a receiving home three more times despite court orders to stay. After her probation was ultimately revoked for these violations, the court ordered her incarcerated at a youth center, and she appealed, arguing her incarceration violated her constitutional right to be free from governmental control absent a compelling state interest.
Whether incarcerating a minor at a youth center for willfully being in criminal contempt of a court order violates the minor's constitutional right to due process.