Juvenile Court has traditionally been though of, within American jurisprudence, as an appendage of the state acting as parens patriae. This obligation dates back to the ancient role of the sovereign as protector of helpless children. An abundance of case law has con- strued and reinterpreted this doctrine, but none has significantly deviated from the general definition. Therefore, the description given in Black's Law Dictionary that parens patriae refers ". . to the sovereign power of guardianship over persons under disability . . . such as minors . . ." will suffice for the purposes of the ensuing discussion. These individuals include delinquent, dependent, and ne- glected children.
M.J. Zarenski, Blood Transfusions and Elective Surgery: A Custodial Function of an Ohio Juvenile Court, 23 Clev. St. L. Rev. 231 (1974)