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Juveniles Adult Court
Motion for Exceptional Down- Youth as Mitigation (3.2023)
This sentencing memo argues the court should depart down based on youth of defendant and lack of contact with police/criminal justice system. Thanks to Brooke Foley.
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Miller Timeline- Sentencing Youth/Young Adults (3.2023)
This document includes a summary of US and Washington caselaw and Washington State legislation relating to fair and constitutional sentencing of youth and young adults.
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Motion for Juvenile/Young Adult Specific Jury Instruction (08.2019)
Based upon scientific research and landmark cases recognizing that children and young adults are different, the defense proposes juvenile or young adult specific jury instructions. Thanks to Ryan McGowan, WDA Legal Extern, 3L.
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Constitutional Challenge to Auto-Decline and Motion to Transfer(8.2017)
This brief asks the Superior Court to transfer a case back to juvenile court for a decline hearing and argues that the automatic decline statute is unconstitutional. The WA Supreme Court later rejected this argument in 2018 in S...
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St v. Sean Thompson (PFR Washington Supreme Court)(2016)
This petition for review to the Washington Supreme Court argues that the POAA is unconstitutional because a trial court cannot take into consideration youth or developmental maturity at the time of a strike offense.
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St v. Ramos (Washington Supreme Court)
At age 14, Joel Ramos waived decline and plead guilty to four counts of murder. He received an 80 year sentence, and when resentenced later 85 years. This appeal argues his sentence is unconstitutional under the 8th A, that the tr...
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St v. Houston Sconiers (Wa Supreme Court)(8.2016)
Auto Decline is unconstitutional (and other issues).
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St v. Roberts-Auto Decline is Unconstitutional (WA Supreme)(9.2016)
Auto-decline is unconstitutional. Thanks to Kathryn Russell Selk.
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St v. N.N.
Consecutive LWOP sentences of a juvenile convicted of two counts of aggravated murder and other counts violate 8th A and Alleyne. Thanks to Kathryn Russel Selk
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Letter to Prosecutor – Youth as Mitigation
This sample letter asks the prosecution to consider youth/adolescent brain development in settling a case filed in adult felony court and is appropriate for declined youth or young adults 18 to 25. Thanks to Colleen O’Conner...
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