Justia Juvenile Law Opinion Summaries

A child, Baby Boy B (BBB), was removed from his mother, JB, shortly after birth and placed in shelter care with his maternal grandmother. The King County Superior Court held shelter care hearings in April, May, and June, finding no contested issues and maintaining prior orders. The court then decided not to hold additional hearings unless there was a motion alleging a change in circumstances, based on King County Superior Court Local Juvenile Court Rule (LJuCR) 2.5.The trial court found that JB's requests for 30-day shelter care hearings were unnecessary and a waste of judicial resources, as her visits were unsupervised. The court stated it would hear motions under LJuCR 2.5 if new issues arose. On discretionary review, the Court of Appeals affirmed the trial court's decision, interpreting the statute to not require monthly review hearings for continued shelter care and finding that LJuCR 2.5 was not contrary to RCW 13.34.065(7)(a)(i).The Supreme Court of the State of Washington reviewed the case and concluded that RCW 13.34.065(7)(a)(i) requires trial courts to hold shelter care review hearings every 30 days while the dependency decision is pending, unless there is a valid waiver or agreed continuance. The court emphasized that ongoing judicial oversight is necessary to ensure the health, welfare, and safety of the child, and to hold parties accountable. The court found that King County LJuCR 2.5 was inconsistent with the statute. Consequently, the Supreme Court reversed the Court of Appeals and remanded the case to the trial court for further proceedings consistent with its opinion. View "In re Dependency of Baby Boy B." on Justia Law

The case involves a mother, Heather, who moved with her three children from Minnesota to Washington to escape domestic violence. After their arrival, the family experienced intermittent homelessness, and the children faced developmental and mental health challenges. Heather also struggled with mental health and substance abuse issues. The children's school reported potential physical abuse to the Department of Children, Youth, and Families (DCYF), leading to the children being placed in emergency shelter care.The King County Superior Court ordered the children into emergency shelter care, and the Court of Appeals denied review. Heather sought review of the shelter care order in the Washington Supreme Court. Department II of the Supreme Court reversed the shelter care order due to the State's failure to apply the "active efforts" standard required by the Indian Child Welfare Act (ICWA) and the Washington State Indian Child Welfare Act (WICWA). The case was remanded for further fact-finding. On remand, the trial court kept the children in shelter care, finding that returning them to Heather would place them in substantial and immediate danger.The Washington Supreme Court reviewed whether RCW 13.04.033(3) requires a lawyer to obtain "specific direction" from a client before seeking appellate review in child welfare cases. The court held that the statute does require such specific direction but does not mandate a separate sworn document or client signature. A notice of appeal or discretionary review filed under RAP 5.3 satisfies the requirement. The court reversed the Court of Appeals' decision, which had dismissed the review due to the lack of a sworn, signed statement from Heather. However, as the case was moot, the Supreme Court remanded it to the trial court for any further necessary proceedings. View "In re Dependency of A.H." on Justia Law

Michael Reynolds Jr. received a mandatory sentence of life in prison without possibility of parole for a crime he committed at age 33. The events triggering that sentence, though, were his two “strikes” under Washington’s “three strikes” law—one of which Reynolds committed at age 17, when he was a juvenile. If Reynolds’ current sentence constituted punishment for his earlier offense committed at age 17, then it would be unconstitutional under case law. But under the Washington Supreme Court’s more recent precedent, his current sentence did not constitute punishment for that prior offense. In Washington v. Moretti, decided two years after Bassett, the Supreme Court held that a “three strikes” sentence of mandatory life in prison without possibility of parole constituted punishment for the last crime or third “strike,” not the earlier first or second “strikes.” “And for years, we have held that our state’s ‘three strikes’ law as applied to adults does not violate article I, section 14.2 That assessment could certainly change over time. But in this case, the parties have not asked us to overrule it.” The Court therefore affirmed the Court of Appeals. View "Washington v. Reynolds" on Justia Law

Petitioner James Hinton was 17 when he was convicted of murder and attempted murder. He received a 37-year standard range adult sentence. In his personal restraint petition (PRP), Hinton argued he was less culpable than an adult when he committed those crimes, so his standard range adult sentence was a disproportionate punishment that violated the Eighth Amendment to the United States Constitution. Hinton sought collateral relief in the form of a resentencing hearing so he could prove that his lesser culpability entitled him to a lesser sentence. The State argued RCW 9.94A.730 was an adequate remedy that precluded Hinton’s PRP under RAP 16.4(d). To this, the Washington Supreme Court agreed: RCW 9.94A.730 was an adequate remedy that precluded Hinton’s PRP because it eliminated the constitutional error that Hinton identified in his original sentence. View "In re Pers. Restraint of Hinton" on Justia Law

This case concerned the adequacy of the Washington early release statute, RCW 9.94A.730, as a remedy to petitioner Erik Carrasco’s alleged unconstitutional sentence for a crime he committed as a juvenile. Carrasco was serving a 93-year sentence imposed without any consideration of his youth. Carrasco was 17 years old and a member of “La Raza,” a Norteño gang in Yakima; he was ultimately convicted of second degree murder, four counts of first degree assault, and second degree unlawful possession of a firearm. He would be eligible to petition for early release under RCW 9.94A.730 after serving 20 years of his sentence. Because Washington v. Scott, 416 P.3d 1182 (2018) was controlling, the Washington Supreme Court concluded Carrasco had an adequate remedy under the statute. The judgment dismissing his personal restraint petition was affirmed. View "In re Pers. Restraint of Carrasco" on Justia Law

When J.W.M. was 17½ years old, he pointed what he thought was an unloaded gun at his friend W.B. and pulled the trigger. The gun was loaded, it discharged, W.B. died two days later. The State charged J.W.M. with first degree manslaughter while being armed with a firearm and unlawful possession of a firearm (UPFA). Because first degree manslaughter was a serious violent offense subject to the Washington “auto-decline” statute, RCW 13.04.030(1)(e)(v)(A), J.W.M. was tried in adult court, and a jury found him guilty of second-degree manslaughter, a lesser included offense. The trial court found him guilty of UPFA in a bifurcated bench trial. With neither offense being an auto-decline offense, J.W.M. was not sentenced in adult court but instead proceeded to a juvenile disposition hearing. More than two weeks before the disposition hearing, for the first time the State recommended a manifest injustice disposition. The juvenile court imposed the maximum possible manifest injustice upward disposition: confinement until age 25. J.W.M. challenged his disposition on several grounds, including that the juvenile court’s primary reason for imposing the disposition was J.W.M.’s need for treatment and services was an invalid basis under our decision in State v. B.O.J., 449 P.3d 1006 (2019). The Washington Supreme Court agreed a new disposition hearing was required, as a manifest injustice disposition was not justified by a juvenile offender’s need for services. View "Washington v. J.W.M." on Justia Law

Petitioner Li’Anthony Williams was 17 years old in 2001 when he pleaded guilty to assault in the second degree with sexual motivation and was sentenced under the indeterminate sentencing scheme for sex offenders. The trial court imposed the statutory maximum term of life with a minimum term at the bottom of the three to nine month standard range. Williams was transferred to the Department of Corrections (DOC) with the understanding that his release date would be determined by the Indeterminate Sentence Review Board (ISRB or Board). The ISRB found Williams was not releasable. Williams in turn filed a personal restraint petition (PRP) on grounds that his maximum term of life sentence was unconstitutional and that he was sentenced to a nonexistent crime. Williams also argued his petition was not barred by the one-year time limit for two reasons: (1) his claim was based on Washington v. Houston-Sconiers, 391 P.3d 409 (2017), which was a significant, material change of law that should be retroactively applied; and (2) his conviction was invalid on its face. The Washington Supreme Court disagreed with both claims: Williams’ petition failed to meet the time bar exception under RCW 10.73.100(6) because his sentence did not violate the substantive rule of Houston-Sconiers; therefore, Houston-Sconiers was not material to Williams’ claim. Furthermore, Williams’ petition did not meet the exception under RCW 10.73.090 because the State’s failure to specify the intended felony underlying the conviction on the judgment and sentence (J&S) did not render the J&S invalid on its face. The Court therefore dismissed Williams’ petition as untimely. View "In re Pers. Restraint of Williams" on Justia Law

Javier Garza was found guilty of third degree rape when he was 17 years old. Twenty-five years after his adjudication, Garza successfully petitioned for relief from registering as a sex offender. Garza then moved to vacate and seal his juvenile adjudication under RCW 13.50.260(3). The court found it had no authority to vacate juvenile adjudications under this provision and denied the motion. The Court of Appeals affirmed on different grounds, holding that because RCW 13.50.260(3) applied only to “order[s] and findings,” juvenile adjudications did not qualify because adjudications were judgments, not orders. The issue this case presented for the Washington Supreme Court's review was whether a juvenile adjudication could be vacated and sealed under RCW 13.50.260(3). Because the plain language of the statute grants trial courts discretion to vacate and seal both adjudications and diversions, the Supreme Court held that juvenile adjudications could be vacated and sealed under RCW 13.50.260(3). The Court reversed the Court of Appeals and remanded for a new hearing. View "Washington v. Garza" on Justia Law

Tonelli Anderson petitioned the Washington Supreme Court for review of his 61-year sentence he received for two first degree murders committed at age 17. Anderson asked the Court to find his sentence was unconstitutionally cruel under the Washington constitution, arguing that Washington v. Haag announced a bright line rule that no juvenile offender could ever receive a sentence of 46 years or longer, no matter how serious or numerous their crimes might be. The Supreme Court agreed that Haag limited the category of juvenile offenders who could receive a de facto life without parole (LWOP) sentence, but when the offender’s crimes do not reflect those “mitigating qualities of youth,” Washington’s constitution does not bar a de facto LWOP sentence. In light of the evidence presented at trial, the Supreme Court concluded the trial court appropriately determined Anderson’s crimes did not reflect “youthful immaturity, impetuosity, or failure to appreciate risks and consequences.” Therefore his sentence was affirmed. View "Washington v. Anderson" on Justia Law

Petitioner Antoine Davis was 21 when he was convicted of first degree murder and second degree attempted murder. He received a standard range sentence of 767 months. Davis filed this personal restraint petition (PRP) more than one year after his judgment and sentence finalized, contending it was. timely for two reasons: (1) In re Personal Restraint of Monschke, 482 P.3d 276 (2021) constituted a significant, material, and retroactive change in law that applied to his de facto life sentence; and (2) recent advances in neuroscience for late-aged adolescents qualified as newly discovered evidence. The Washington Supreme Court found: (1) Monschke applied to 19- and 20-year-old defendants; and (2) Davis did not satisfy any of the statutory criteria that exempted his petition from the one-year time bar. View "In re Pers. Restraint of Davis" on Justia Law