14th Amend. Also seems to support the right for juveniles to receive rehabilitative services.
Possible reason for difference between treatment of adults and juveniles is that the juvenile justice system’s orientation is toward rehabilitation rather than punishment as in the (adult) criminal justice system.
As was pointed out in a 1999 study done by the Institute of Law, Psychiatry and Public Policy at U.Va., there are few cases elaborating on this use of the 14th Amend, probably because many of the cases are settled before judgment.
Nonetheless, there are several federal cases indicating that those civilly committed (as juveniles usually are) have a 14th Amend. Right to receive such training as an appropriate professional would consider reasonable. (Youngberg v. Romero)
Thus, much discretion is afforded to professional staff in assessing what constitutes “reasonable training and/or rehabilitation