The district court noted benefits accorded juveniles unavailable to adults, declined to intervene in the jurisdiction of an ongoing confinement (Puerto Rico), and cited the O'Conner v. Donaldson opinion as reason to reject right to treatment claims. The juvenile right to treatment debate has been waged for some time but not considered in the context of the Donaldson case which concerned confinement of a nondangerous mentally ill patient for 15 years without therapeutic treatment. In his concurring opinion, Chief Justice Burger observed that "a State's police power may justify confinement of individuals solely to protect society ..." Whether confinement without rehabilitation is a legitimate exercise of the court's parens patriae authority in juvenile justice remains the real issue which is reviewed historically with citations. 33 references.