State Of Washington, V Aaron Ata Toleafoa, 49152-4

At age 15, Aaron Toleafoa committed a series of violent crimes including burglary, multiple vehicle thefts, armed robbery, and shooting a person; he pleaded guilty to multiple felonies including attempted second-degree murder and first-degree robbery.
The trial court acknowledged youth could be a mitigating factor but denied an exceptional downward sentence, finding Toleafoa acted in an adult-like manner and was not living the life of a typical juvenile.
The court imposed standard-range sentences, with a maximum aggregate of 260 months’ incarceration.
Toleafoa appealed, arguing the sentencing court failed to meaningfully consider his youth, including immaturity, rehabilitation potential, and the role of peer/family pressures.
After sentencing but before resolution of this appeal, the Washington Supreme Court decided State v. Houston‑Sconiers, which requires trial courts to consider specified youth-related factors and retain discretion to impose below‑range sentences for juveniles.
Because Houston‑Sconiers was issued while the appeal was pending and the trial court did not address all mandatory Houston‑Sconiers factors, the Court of Appeals remanded for resentencing so the trial court can fully consider those factors.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly considered juvenile status when denying a below‑range sentence	Toleafoa: court failed to consider required youth-related mitigating factors (immaturity, environment/family/peer pressures, rehabilitation potential) per Houston‑Sconiers	State: trial court considered youth and mitigation and permissibly denied a below‑range sentence based on facts of this case	Court: trial court considered some youth factors but not all mandatory Houston‑Sconiers factors (decision predated that case); remand for resentencing so court can fully consider those factors

State v. Houston‑Sconiers, 188 Wn.2d 1 (2017) (trial courts must consider specified mitigating qualities of youth and retain discretion to impose below‑range juvenile sentences)
State v. O’Dell, 183 Wn.2d 680 (2015) (youth can be a substantial and compelling factor justifying below‑range sentences)
Miller v. Alabama, 567 U.S. 460 (2012) (juvenile sentencing must account for hallmark features of youth and potential for rehabilitation)
State v. Law, 154 Wn.2d 85 (2005) (nonstatutory mitigating factors must relate to the crime, defendant culpability, or criminal history)