Washington v. D.L. (Majority and Concurrence)
Annotate this CaseIn 2017, D.L., a 14-year-old boy, was charged with three counts of first degree rape and one count of attempted first degree rape of his 5-year-old half brother. At the time, D.L. had no prior criminal history. D.L. successfully negotiated a plea deal with the prosecutor, reducing the charges to a single count of first degree attempted child molestation. D.L. stipulated in his plea agreement that the trial court could use the probable cause statement to determine the facts that supported his conviction. But when the court imposed the manifest injustice disposition, it relied on three facts that were not in the probable cause affidavit: (1) that D.L.’s victim had a cognitive disability; (2) that D.L. refused accountability; and (3) that D.L. would not cooperate with treatment. This case asked the Washington Supreme Court whether due process required that the State give a juvenile notice of these specific facts before pleading guilty if they will be used to justify a manifest injustice disposition. "Ultimately, due process requires that juveniles be treated in a manner that is fundamentally fair. ... Without adequate notice, juveniles and their attorneys cannot predict which facts might be unearthed and weaponized to extend the juvenile’s sentence after the plea. This lack of notice causes unfair surprise to young defendants and serves only to undermine juveniles’ and their families’ trust in our juvenile justice system. Our adult defendants in Washington are not treated so unfairly and neither should we so treat our juveniles." As a result, the manifest injustice disposition was improperly imposed. As D.L. already served his sentence and this case was technically moot; the Court resolved this legal issue without modifying D.L.’s sentence.
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