State Of Washington, V Christopher Daniel Holt, Jr., 53122-4

Background

In 2008 Holt (age 17) pleaded guilty in adult court to second‑degree murder under a plea agreement that specified a 216‑month sentence; his offender score at sentencing was 1.
The plea removed firearm enhancements and avoided first‑degree murder exposure; the agreed 216 months fell within the SRA standard range then used.
After State v. Houston‑Sconiers (2017) required adult courts to consider mitigating qualities of youth at sentencing, Holt filed a CrR 7.8 motion (2017) seeking relief and a resentencing hearing to present youth‑mitigation evidence.
The trial court denied relief, declined to transfer the CrR 7.8 motion to the Court of Appeals as a PRP, and refused an evidentiary resentencing hearing on the ground that admitting mitigation evidence would breach the plea agreement (citing State v. Sledge).
On appeal the Court of Appeals converted the matter to a PRP, held Houston‑Sconiers is material to Holt’s sentence but that Holt must elect to withdraw his plea to obtain an evidentiary mitigation resentencing; the court also granted relief under State v. Blake and remanded for resentencing with a corrected offender score of 0.

Issues

Issue	Holt's Argument	State's Argument	Held
Whether the trial court should have transferred/treated the CrR 7.8 motion as a PRP	Trial court erred by denying rather than transferring; CrR 7.8(c)(2) required transfer absent findings	Trial court acted within discretion	Court converted the appeal to a PRP and proceeded on PRP standards (transfer appropriate)
Whether Houston‑Sconiers is a significant change in law material to Holt despite an agreed sentence	Houston‑Sconiers applies retroactively and is material because Holt was sentenced as an adult for crimes committed as a child	Not material because Holt agreed to a specific sentence	Houston‑Sconiers is material to Holt’s case (applies to adult SRA sentences for juvenile crimes)
Remedy under Houston‑Sconiers: entitlement to evidentiary resentencing with youth witnesses without withdrawing plea	Holt sought a resentencing hearing with witnesses to present youth mitigation while keeping the 216‑month sentence	Allowing such a hearing would breach plea contract and permit State to present aggravation, undermining plea; remedy inappropriate without plea withdrawal	Holt is not entitled to an evidentiary mitigation resentencing while remaining bound to the plea; to pursue an exceptional downward sentence he must first elect to withdraw his plea and show he would not have pleaded guilty if informed of his rights
Effect of State v. Blake on offender score and sentence	Blake voids certain drug convictions used to calculate offender score; Holt’s score should be 0 and he must be resentenced	State concedes Blake requires correcting offender score and resentencing	Court orders resentencing under the correct offender score (remand for resentencing consistent with Blake)

Key Cases Cited

State v. Houston‑Sconiers, 188 Wn.2d 1 (2017) (Eighth Amendment requires sentencing courts to consider mitigating qualities of youth and permits downward departures)
In re Pers. Restraint of Ali, 196 Wn.2d 220 (2020) (Houston‑Sconiers is a significant, retroactive change in law material on collateral review)
In re Pers. Restraint of Domingo‑Cornelio, 196 Wn.2d 255 (2020) (Houston‑Sconiers applies to any SRA range or enhancement for juvenile offenses)
State v. Blake, 197 Wn.2d 170 (2021) (invalidates strict‑liability drug possession convictions; may require vacating certain prior convictions used in offender‑score calculations)
State v. Sledge, 133 Wn.2d 828 (1997) (prosecutor’s conduct that undermines a joint sentencing recommendation breaches plea agreement)
State v. Wilson, 170 Wn.2d 682 (2010) (resentencing is required when a defendant was sentenced under an incorrect offender score despite an agreed plea)
In re Pers. Restraint of Garcia‑Mendoza, 196 Wn.2d 836 (2021) (remand for reference hearing where a new rule is retroactive and material to determine if plea withdrawal is justified)
Miller v. Alabama, 567 U.S. 460 (2012) (children are constitutionally different from adults for sentencing purposes)