State Of Washington, V. C.m.h., 81339-1

Appellant C.M.H., age 16 at the time, pleaded guilty to first‑degree rape of a child and first‑degree child molestation; each victim was six and the offenses were ~4 months apart.
At the March 11, 2020 dispositional hearing C.M.H. requested a downward "manifest injustice" disposition below the juvenile standard range.
The juvenile court denied the manifest‑injustice request and imposed standard‑range dispositions of 30–40 weeks J.R. time for each count, to run consecutively.
The court considered statutory mitigating and aggravating factors, C.M.H.’s trauma history, and a probation report finding a high risk of reoffense.
The court found insufficient evidence that a mental or physical condition significantly reduced culpability (the key mitigating factor relied on by defense) and found aggravating factors: particularly vulnerable victims, sex offenses, and risk to reoffend.
On appeal, C.M.H. argued the denial was an abuse of discretion; the Court of Appeals affirmed, holding the juvenile court’s decision was supported by the record and not a manifest abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused its discretion by denying a downward "manifest injustice" disposition	State: the court properly weighed statutory mitigating and aggravating factors and permissibly denied a downward disposition	C.M.H.: the court erred by refusing a downward manifest‑injustice disposition given youth/trauma and mitigating evidence (relying on counsel's declaration)	Denial affirmed—no manifest abuse of discretion; court reasonably found insufficient clear and convincing evidence of the claimed mitigating mental/physical condition and relied on valid aggravating factors and risk assessment

State v. McGill, 112 Wn. App. 95 (2002) (standard‑range sentences generally unappealable except to challenge underlying legal determinations)
State v. McFarland, 189 Wn.2d 47 (2017) (defendants are entitled to have exceptional sentence requests actually considered)
State v. B.O.J., 194 Wn.2d 314 (2019) (standards for reviewing manifest‑injustice dispositional decisions and weighing statutory factors)
State v. M.L., 134 Wn.2d 657 (1998) (once manifest injustice is found, trial court has broad sentencing discretion)
State v. Houston‑Sconiers, 188 Wn.2d 1 (2017) (courts must consider mitigating qualities of youth when sentencing)
Miller v. Alabama, 567 U.S. 460 (2012) (youthful characteristics bear on sentencing and culpability)