Justia Juvenile Law Opinion Summaries

In 1992 when Jeremiah Gilbert was a juvenile, he was charged and convicted of aggravated murder, premeditated murder, and multiple other crimes. He was sentenced to life without parole for the aggravated murder along with a consecutive sentence for the premeditated murder, as required under the laws in effect at that time. When RCW 10.95.035 was enacted, Gilbert became entitled to a new sentencing hearing. During his resentencing, Gilbert argued that the judge should restructure his two sentences such that they would run concurrently. However, the judge ruled that he lacked Statutory authority to address anything other than Gilbert's sentence for aggravated murder and imposed a sentence of 25 years to life, leaving intact the consecutive sentence of 280 months for the premeditated murder conviction. The Court of Appeals affirmed. The Washington Supreme Court found that because the judge presiding over Gilbert's resentencing believed he did not have discretion to consider anything other than an adjustment to the aggravated murder sentence, he did not consider whether the mitigating factors of Gilbert's youth might warrant an exceptional sentence. The Court found this to be error: Gilbert was entitled at his resentencing to consideration of an exceptional sentence in light of the potential mitigating factors of his youth. Therefore, the Supreme Court reversed and remanded for that consideration. View "Washington v. Gilbert" on Justia Law

When Brian Bassett was 16 years old, he was living in a "shack" with Nicholaus McDonald after Bassett's parents '"kicked [him] out'" of their home. With McDonald's assistance, Bassett snuck back into his home and shot his mother and father. His brother was drowned in the bathtub, an act that McDonald initially confessed to but later blamed on Bassett at trial. Bassett was convicted of three counts of aggravated first degree murder for the deaths of his mother, father, and brother. The judge commented that Bassett was "a walking advertisement" for the death penalty and sentenced him to three consecutive terms of life in prison without the possibility of parole. At issue here was the constitutionality of sentencing juvenile offenders to life in prison without the possibility of parole or early release. The State appealed a Court of Appeals decision holding that the provision of Washington's Miller-fix statute that allows 16- and 17-year-olds to be sentenced to life without parole violated the Washington Constitution's ban on cruel punishment. The appellate court adopted the categorical approach, rather than Washington's traditional Fain proportionality test, and found that sentencing juvenile offenders to life without parole or early release constituted cruel punishment. The Washington Supreme Court affirmed the Court of Appeals' decision and held that sentencing juvenile offenders to life without parole or early release constitutes cruel punishment and therefore is unconstitutional under article I, section 14 of the Washington Constitution. View "Washington v. Bassett" on Justia Law

Sixteen-year-old Tyler Watkins was charged with first degree burglary as an adult. The former RCW 13.04.030(1) (2009) provided that juvenile courts had to automatically decline jurisdiction over 16- and 17-year-olds charged with certain offenses. Watkins argued his due process rights were violated because the automatic decline component of the statute applied without him first having a hearing on whether the juvenile court should have retained jurisdiction. The Washington Supreme Court held the automatic decline did not violate due process because juveniles did not have a constitutional right to be tried in juvenile court. View "Washington v. Watkins" on Justia Law

This case addressed the adequacy of the parole remedy available under RCW 9.94A.730, the Miller "fix" statute. Jai'Mar Scott was convicted by a jury in 1990 of first degree premeditated murder for killing his neighbor, a 78-year-old-woman who suffered from Alzheimer's disease. Scott was 17 years old when he committed the murder. The juvenile court declined jurisdiction, and Scott was tried, convicted, and sentenced as an adult. At sentencing, the parties agreed that the standard range was 240 to 320 months, with 240 months being the mandatory minimum sentence that could be imposed. The State requested an exceptional sentence above the standard range. The defense requested the low end of the standard range. The trial court sentenced Scott to an exceptional sentence of 900 months based on four independent findings: (1) that Scott's conduct constituted deliberate cruelty, (2) that his conduct was an abuse of trust, (3) that the crime involved multiple injuries, and (4) that the victim was particularly vulnerable. On direct appeal, the Court of Appeals held that the 900-month sentence imposed was not clearly excessive because the "aggravating factors are both numerous and individually and collectively egregious." The Court of Appeals also rejected Scott's assertion that his exceptional sentence was improper in light of his youth at the time of the crime. The Washington Supreme Court affirmed: consistent with the federal Supreme Court’s decision in Montgomery v. Louisiana, 136 S. Ct. 718 (2016), the Washington Court held that RCW 9.94A.730's parole provision was an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile. View "Washington v. Scott" on Justia Law

This case addressed the adequacy of the parole remedy available under RCW 9.94A.730, the Miller "fix" statute. Jai'Mar Scott was convicted by a jury in 1990 of first degree premeditated murder for killing his neighbor, a 78-year-old-woman who suffered from Alzheimer's disease. Scott was 17 years old when he committed the murder. The juvenile court declined jurisdiction, and Scott was tried, convicted, and sentenced as an adult. At sentencing, the parties agreed that the standard range was 240 to 320 months, with 240 months being the mandatory minimum sentence that could be imposed. The State requested an exceptional sentence above the standard range. The defense requested the low end of the standard range. The trial court sentenced Scott to an exceptional sentence of 900 months based on four independent findings: (1) that Scott's conduct constituted deliberate cruelty, (2) that his conduct was an abuse of trust, (3) that the crime involved multiple injuries, and (4) that the victim was particularly vulnerable. On direct appeal, the Court of Appeals held that the 900-month sentence imposed was not clearly excessive because the "aggravating factors are both numerous and individually and collectively egregious." The Court of Appeals also rejected Scott's assertion that his exceptional sentence was improper in light of his youth at the time of the crime. The Washington Supreme Court affirmed: consistent with the federal Supreme Court’s decision in Montgomery v. Louisiana, 136 S. Ct. 718 (2016), the Washington Court held that RCW 9.94A.730's parole provision was an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile. View "Washington v. Scott" on Justia Law

Evan Bacon, a juvenile, pleaded guilty to second degree robbery and received a suspended disposition. The State challenged the juvenile court's authority to enter such a disposition, arguing that the Juvenile Justice Act of 1977 (JJA), chapter 13.40 RCW, does not give trial courts the statutory authority to suspend juvenile dispositions (except in specific situations that are absent here). The Court of Appeals agreed, and so did the Washington Supreme Court. The Court therefore affirmed, holding that juvenile court judges lack statutory authority to suspend JJA dispositions, even manifest injustice JJA dispositions, unless the disposition fits under one of the specifically listed exemptions in RCW 13.40.160(10). View "Washington v. Bacon" on Justia Law

Brian Buckman pleaded guilty to second degree rape of a child. After sentencing, Buckman learned that he had been misinformed of the sentencing range that applied to him. Based on this misinformation, Buckman sought to withdraw his plea as involuntary. Because Buckman's motion to withdraw was a collateral attack on his judgment and sentence, he had to show that his plea was involuntary, and actual and substantial prejudice resulting from that error. The Washington Supreme Court concluded Buckman's plea was involuntary because he was misinformed that he might be sentenced to life in prison despite the fact that the statute provided that a sentence of life in prison could not apply to a 17-year-old (Buckman's age at the time of the offense). But the Court also held he was not entitled to withdraw his plea because he failed to show that the misinformation provided at the time of his plea caused him actual and substantial prejudice. As a result, the Supreme Court denied the motion to withdraw and remanded for resentencing only. View "Washington v. Buckman" on Justia Law

As a juvenile homicide offender facing a de facto life-without-parole sentence, petitioner Joel Rodriguez Ramos was entitled to a "Miller" hearing, just as a juvenile homicide offender facing a literal life-without-parole sentence would be. Based on the record presented, the Supreme Court found that that Ramos received a constitutionally adequate Miller hearing and he did not show that his aggregated 85-year sentence violated the Eighth Amendment. View "Washington v. Rodriguez Ramos" on Justia Law

Juvenile defendant Trey M. challenged his three convictions for felony harassment under RCW 9A.46.020. The Court of Appeals certified the issue to the Washington Supreme Court of whether the United States Supreme Court's decision in "Elonis v. United States," (135 S. Ct. 2001 (2015)) had any impact on the Washington Court's "reasonable person standard" for what constituted a "true threat" under the First Amendment to the United States Constitution. The Washington Supreme Court held that because "Elonis" expressly avoided any First Amendment analysis, it provided no basis for the Court to abandon its established First Amendment precedent. Accordingly, the Court affirmed. View "Washington v. Trey M." on Justia Law

K.H.-H., a 17-year-old male, was charged with assault with sexual motivation after he forced himself on C.R., a female acquaintance who attended the same high school. The issue this case presented on appeal involved whether a juvenile disposition condition requiring K.H.-H. to write an apology letter to the victim violated his constitutional free speech rights. After review, the Supreme Court held that it did not. View "Washington v K. H.-H." on Justia Law