Washington v. B.O.J. (Majority, Concurrence and Dissent)
Annotate this CaseIn a moot case of substantial and continuing public interest, a juvenile offender challenges whether her need for treatment was an appropriate basis for imposing a manifest justice disposition. B.O.J. pled guilty to two counts of third degree theft for shoplifting from a grocery store. These offenses subjected her to a "local sanctions" standard sentencing range. In exchange for a plea, the prosecution promised to recommend 6 months of community supervision, 8 hours of community service, credit for time served, release at her sentencing disposition, and no contact with the victims. One month later, the State contended B.O.J. violated the conditions of her release by running away from placement. The State thereafter recommended a manifest justice disposition with confinement in a Juvenile Rehabilitation Administration facility. The trial court stated its findings that both B.O.J.'s need for treatment and the standard sentencing range as too lenient supported the manifest injustice disposition. The Washington Supreme Court determined the trial court's findings were not an appropriate basis for imposing a manifest injustice disposition. The Court reversed the Court of Appeals' holding that B.O.J.'s need for treatment supported the trial court's finding that a standard range disposition would effectuate a manifest injustice.
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