The U.S. Supreme Court recently considered the constitutionality of preadjudication juvenile detention in Schall v. Martin (1984). The Court explained that juveniles do have a fundamental liberty interest but noted that 'the juvenile's liberty interest may, in appropriate circumstances, be subordinated to the state's parens patriae interest in preserving and promoting the welfare of the child.' Florida is not sufficiently careful about its decisions regarding juvenile detention, due primarily to broad statutory detention criteria. Unnecessary detention is an infringement upon fundamental liberty, a destructive experience for troubled youth, and a violation of community aims for juveniles. Florida should adopt a two-step decisionmaking process for juvenile detention that incorporates both due process and parens patriae concerns. In the first step, the court would hold a hearing and apply strict criteria to determine whether the juvenile poses a substantial danger to the community or a substantial risk of nonappearance. If these criteria are satisfied, the juvenile could be detained in a secure facility. If the criteria are not satisfied, the court would move to the second step, which would apply parens patriae criteria to the detention decision. Should detention be ordered under the second step, the juvenile would be placed in a program that provides services needed by the juvenile. 31 notes.