State Of Washington v. Alem Skrobo, 485 P.3d 333

In 2013 Skrobo petitioned for and the district court granted a five‑year deferred prosecution for DUI and reckless driving, with a court‑approved two‑year alcoholism treatment program and conditions (abstinence, law‑abiding conduct, etc.).
The deferred prosecution order expressly deferred prosecution for five years from entry but required a two‑year treatment program.
In January 2018 the State moved to revoke Skrobo’s deferred prosecution after new charges (hit‑and‑run, DUI, reckless endangerment) arose while the deferred prosecution remained pending.
The district court revoked the deferred prosecution and later entered judgment and sentence on the underlying charges; Skrobo’s reconsideration motion was denied.
The superior court reversed, holding the district court lacked statutory authority to revoke after the two‑year treatment period had ended (i.e., only the two‑year alcoholism program was revocable).
The State obtained discretionary review in the Court of Appeals, which reversed the superior court and held courts may revoke a deferred prosecution at any time during the five‑year deferred prosecution period.

Issue	State's Argument	Skrobo's Argument	Held
Whether a court may revoke a deferred prosecution after the two‑year alcoholism treatment period but before dismissal at five years	The statute permits revocation during the entire five‑year deferred prosecution period; "deferred prosecution program" ≠ only the two‑year alcoholism program	"Deferred prosecution program" should be read as the two‑year alcoholism program, so revocation authority ends when treatment ends	Court of Appeals: revocation authority extends throughout the five‑year deferred prosecution period; statutes reasonably read together to avoid absurd results

State v. Conover, 183 Wn.2d 706 (2015) (statutory‑interpretation principles; rule of lenity only if statute ambiguous)
State v. Roggenkamp, 153 Wn.2d 614 (2005) (give effect to all statutory language)
State v. Ervin, 169 Wn.2d 815 (2011) (avoid interpretations that produce absurd results; use context to resolve ambiguity)
Abad v. Cozza, 128 Wn.2d 575 (1996) (deferred prosecution is a creature of statute; court authority measured by statute)
City of Seattle v. May, 151 Wn. App. 694 (2009) (standard for superior court review of district court under RALJ 9.1)
State v. Wright, 54 Wn. App. 638 (1989) (limitations on district court authority for deferred prosecution are statutory)