Summary of Argument

Children are different from adults, and two children of the same age can be very different from one another. Over the last decade, both this Court and the United States Supreme Court have recognized that these differences are of constitutional significance, and have thus repeatedly struck down sentencing schemes that do not allow consideration of a defendant’s youthfulness.

Washington’s “auto-decline” statute, in concert with the state’s adult sentencing laws, creates precisely the kind of impermissible scheme that recent case law has rejected. Under the auto-decline statute, a 16- or 17-year-old defendant charged with certain crimes is automatically tried in adult court, with no opportunity to demonstrate that his or her youthfulness and related characteristics make trial as an adult inappropriate. If the teenage defendant is convicted, he or she is automatically sentenced as an adult. In some cases—including this one— the defendant is subject to mandatory enhancements that result in decades- long sentences plainly inappropriate for the vast majority of juveniles.

Even where mandatory enhancements do not apply, a teenage defendant bears the burden to prove that his or her characteristics warrant an exceptional downward sentence, creating a perverse presumption that children are adults until proven otherwise. In either case, juvenile defendants subject to auto-decline face a significant probability of receiving sentences that are disproportionate in light of their youthfulness. At least until substantial new safeguards are enacted for youth defendants sentenced in adult courts, that probability renders the auto-decline statute unconstitutional under both article I, section 14 and the Eighth Amendment.

Summary of Argument

The fundamental differences between children and adults, along with the significant variations within the juvenile population, necessitate individualized consideration in the sentencing process. Recent jurisprudence, including decisions from both the United States Supreme Court and this court, has established that failing to acknowledge these differences through sentencing schemes constitutes a violation of constitutional rights.

Washington's “auto-decline” statute, in conjunction with the state's adult sentencing laws, creates a system that directly contravenes the principles upheld in recent case law. Under this statute, defendants aged 16 or 17 facing certain charges are automatically transferred to adult court, eliminating the opportunity for individualized assessments of their youthfulness and mitigating factors. This automatic transfer leads to automatic adult sentencing, potentially subjecting defendants to mandatory enhancements that impose lengthy sentences demonstrably inappropriate for most juveniles.

Even in cases where mandatory enhancements are not applicable, the burden of proof rests on the juvenile defendant to justify an exceptional downward sentence, effectively creating a presumption that youth is irrelevant until proven otherwise. This burden, coupled with the lack of individualized consideration, significantly increases the likelihood of disproportionate sentences for juvenile defendants subject to the auto-decline statute. The absence of robust safeguards for youthful defendants sentenced in adult courts further amplifies this risk, rendering the auto-decline statute unconstitutional under both Article I, Section 14 and the Eighth Amendment.

Summary of Argument

The state of Washington's "auto-decline" statute, which mandates that certain crimes committed by 16- and 17-year-olds be tried in adult court, violates the constitutional rights of juvenile defendants. This statute, in conjunction with the state's adult sentencing laws, creates a system that fails to account for the unique characteristics of youth, effectively treating them as adults without the opportunity to demonstrate why this approach is inappropriate.

This statute disregards the established legal principle that youthfulness warrants individualized consideration in sentencing, a principle upheld by both the Washington State Supreme Court and the United States Supreme Court. It automatically subjects juvenile defendants to adult sentencing, including mandatory enhancements that can result in lengthy prison terms. This creates a situation where youth are presumed to be adults until proven otherwise, placing the burden on them to justify a less severe sentence.

The combination of automatic adult trial, mandatory sentencing enhancements, and the burden of proof placed upon young defendants creates a system where youth are at a significant risk of receiving disproportionately harsh sentences. This system violates the constitutional rights to due process and protection from cruel and unusual punishment, as enshrined in Article I, Section 14 and the Eighth Amendment of the Washington State Constitution.

Summary of Argument

The way the law treats young people is changing. Courts have decided that young people are different from adults, and the law should recognize this. Washington state has a law that automatically sends teenagers to adult court for certain crimes. This means that a 16 or 17 year old can’t even try to show why being tried as an adult wouldn’t be fair. If they’re found guilty, they are automatically sentenced as an adult.

This means that teenagers could get very long sentences, even if they’re not adults yet. The law makes it harder for a young person to show that their age should be considered when they’re sentenced. This means that teenagers often get sentences that are too harsh for their age. This type of law is against the Constitution because it doesn’t fairly consider the differences between adults and teenagers.

Summary of Argument

Washington state has a law called the “auto-decline” law. It says that if a 16 or 17-year-old is charged with serious crimes, they have to be tried in adult court. Lawyers can’t argue that they should be tried as a kid because they’re young, and if they’re found guilty, they’re sentenced like an adult.

In some cases, they even get extra long sentences that are way too long for most kids. Even if they don’t get extra time, the kid has to prove they shouldn’t get a really long sentence. It’s like saying kids are grown-ups unless they prove they’re not! Because of this, kids who are tried as adults might get punishments that are too harsh for how young they are. Until there are better ways to protect kids who are tried as adults, this “auto-decline” law is unfair and goes against the law.