Washington v. Delbosque (Majority)Annotate this Case
In 1994, 17-year-old Cristian J. Delbosque was convicted of aggravated first degree murder and received a mandatory life sentence without the possibility of release. Because he was a juvenile at the time of his offense, Delbosque was resentenced in 2016 in accordance with the Miller-fix statute and received a minimum term of 48 years without the possibility of parole. The Court of Appeals concluded that Delbosque could seek review of his sentence only through a personal restraint petition (PRP), rather than direct appeal, but nevertheless reversed his sentence, holding that the trial court's factual findings were not supported by substantial evidence. The Washington Supreme Court affirmed the Court of Appeals' holding that the sentencing court's findings were not supported by substantial evidence, thus remanding for resentencing was proper. However, the Supreme Court reversed the Court of Appeals' holding that Delbosque was not entitled to a direct appeal.