State Of Washington, V Elijah Isaiah Cofield And Derek M. Jeter
49039-1
| Wash. Ct. App. | Oct 24, 2017Background
- Cofield and Jeter were juvenile offenders whose disposition orders included conditions (restitution for Cofield; community service and apology letter for Jeter). The juvenile court scheduled administrative record-sealing hearings under RCW 13.50.260.
- At the administrative hearings the State objected to sealing both records on the ground that each juvenile had not completed disposition conditions.
- The juvenile court commissioner declined to seal the records and denied requests to set contested record-sealing hearings; superior court denied motions to revise those rulings.
- Cofield and Jeter appealed, arguing that RCW 13.50.260(1) requires a contested hearing whenever any objection to sealing is received at the administrative hearing.
- The Court of Appeals analyzed the plain text of RCW 13.50.260(1), concluding it creates a presumption that records will be sealed at the administrative hearing unless there is an objection or a compelling reason not to seal, in which case a contested hearing must be set.
- The court reversed the superior court, holding that objections based on uncompleted disposition conditions entitle juveniles to contested record-sealing hearings and remanded for those hearings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RCW 13.50.260(1) requires a contested record-sealing hearing when any objection to sealing is raised at the administrative hearing | Cofield/Jeter: any objection at the administrative hearing triggers a mandatory contested hearing under RCW 13.50.260(1)(a) | State: contested hearings are required only when the case is otherwise eligible for sealing; ineligible cases (e.g., uncompleted conditions) need not get contested hearings | Court: RCW 13.50.260(1) is unambiguous; any objection at the administrative hearing (including for uncompleted conditions) requires the court to set a contested hearing |
Key Cases Cited
- State v. Lawley, 91 Wn.2d 654 (1979) (context on JJA reform and juvenile system purposes)
- State v. S.J.C., 183 Wn.2d 408 (2015) (juvenile records deserve greater confidentiality)
- State v. Richardson, 177 Wn.2d 351 (2013) (standard of review for sealing decisions)
- State v. Tobin, 161 Wn.2d 517 (2007) (abuse of discretion can include legal error)
- State v. Gonzalez, 168 Wn.2d 256 (2010) (statutory interpretation reviewed de novo)
- State v. Armendariz, 160 Wn.2d 106 (2007) (primary goal in statutory interpretation is legislative intent)