State v. Harris (Majority, Concurrence and Dissent)
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In 2011, 17-year-old Darren Harris fatally stabbed an acquaintance and stole his wallet. Harris was charged with first-degree murder with a deadly weapon. After negotiations, Harris pleaded guilty to second-degree murder and first-degree robbery, with a joint sentence recommendation of 244 months. The trial court accepted the plea and imposed the recommended sentence.
Harris later filed a personal restraint petition, arguing for resentencing based on the State v. Houston-Sconiers decision, which requires courts to consider the mitigating qualities of youth. The Court of Appeals dismissed the petition as frivolous but later granted Harris an extension to appeal. The Court of Appeals found that Harris had agreed not to seek a lesser sentence and concluded that any resentencing would breach the plea agreement. The court held that Houston-Sconiers applied retroactively but did not require resentencing, suggesting Harris could withdraw his guilty plea instead.
The Supreme Court of Washington reviewed the case and held that when a trial court accepts a plea agreement with a joint sentence recommendation, it is not required to independently consider mitigating evidence of youth under Houston-Sconiers. The court emphasized the importance of plea bargaining in the criminal justice system and concluded that no error occurred when the trial court did not inquire into Harris's youth before accepting the plea agreement. The court reversed the Court of Appeals' decision in part, affirming Harris's sentence and holding that resentencing was not required.
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