How have the courts interpreted the words "cost of care" in section 46-134(2)(c)(i) of the Arizona Juvenile Rights Act?

Ariz.Rev.Stat.Ann. 46-134(2)(c)(i) (Supp.1979) (emphasis added). The appellants read the words "cost of care" in this section to require the state to pay for additional counseling, therapy, education, diagnosis and child care staff. This interpretation is not wholly implausible, given the state judicial emphasis on rehabilitating and treating juveniles within the state's custody. See, e. g., McBeth v. Rose, 111 Ariz. 399, 402, 531 P.2d 156, 159 (1975) (dictum) ("the purpose of the juvenile provisions in Arizona concerns the treatment, not the capacity of the offender").

The third Pullman criterion is also satisfied. The determinative issue of state law is doubtful. The Arizona state courts have never had the opportunity to construe Ariz.Rev.Stat.Ann. 46-134(2)(c)(i). Serious interpretive questions remain unresolved. First, it is unclear whether the state legislature in enacting Ariz.Rev.Stat.Ann. 8-134(2)(c)(i) meant to confer an implied cause of action to individuals to enforce the statute's command. Second, it is unclear what level of care is required under the statute. Compare with McRedmond v. Wilson, 533 F.2d 757, 762-64 (2d Cir. 1976) (Pullman abstention improper in juvenile right to treatment suit where state courts had accepted and given substance to state statutory right to treatment claim).