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2015 Amicus Briefs

State v Bharadwaj
 
Cross v WA
 
St. v. O'Dell
This Amicus brief argues youth should be a mitigating factor that may justify a departure from the standard range and imposition of a exceptional sentence. Sean O'Dell was 18 years and 10 days old when he committed his offense. The trial court followed the existing case law holding youth is not a basis to depart (St. v. Law, St. v. Ha'mim.)
St v. Fedorov
This WDA Amicus Brief argues that a DUI arrestee's right to counsel includes the right to a private conversation with counsel when deciding whether to submit to a DUI breath test.
St v. Solis Diaz
This Amicus argues that the Supreme Court should accept the Motion to Transfer from the COA to address an issue of significance - what it means to factor in youth and all its attendant circumstances at sentencing.
St v. Phet
This Amicus Memorandum urges the COA II to accept John Phet's MDR to determine the mandatory minimum for 5 counts of aggravated murder - does the trial court have discretion to run these concurrent? The trial court said no, the minimum is 125 years. Mr. Phet and WDA/Columbia argue trial courts must have discretion to comply with Miller v. Alabama and the 8th Amendment.
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