Momentum developed in the 1970's for juvenile's right to rehabilitation, but the movement stopped in the 1980's after the First and Ninth Circuit Courts of Appeals rendered adverse decisions. The analysis contends that as participants in civil proceedings that result in incarceration, incarcerated juveniles have a constitutional right to rehabilitation. The rationale for juveniles' right to rehabilitation is similar to the legal rationales used in judicial decisions involving the institutionalized mentally ill and the institutionalized mentally retarded. This reasoning holds that a person cannot be punished for a mere status. The same theory holds for committed juvenile offenders and their right to rehabilitation. The right to rehabilitation may also be found in State laws and thereby acquires constitutional protection. List of cases cited and 13 references