State Of Washington v. Evan Bacon, (dob 3/3/2000)
197 Wash. App. 772
| Wash. Ct. App. | 2017Background
- Juvenile Evan Bacon pleaded guilty to second-degree robbery after taking a purse and using force; victim suffered minor injuries.
- Standard-range disposition based on prior record was 52–65 weeks of confinement; the juvenile court found a manifest injustice to imposing the standard range.
- The juvenile court imposed a 65-week disposition but suspended it and placed Bacon on community supervision with conditions.
- The State appealed, arguing the record didn’t support manifest injustice and, centrally, that the court lacked statutory authority to suspend a disposition outside the limited exceptions in the Juvenile Justice Act (JJA).
- While the appeal was pending, Bacon’s suspended disposition was revoked; the appeals court nonetheless considered the legal question as one of continuing public interest.
- The Court of Appeals reversed, holding the juvenile court had discretion over disposition length after declaring manifest injustice but lacked statutory authority to suspend the disposition here.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Bacon) | Held |
|---|---|---|---|
| Whether a juvenile court may suspend a disposition after declaring a manifest injustice when the JJA otherwise bars suspension | Court cannot suspend a disposition unless an explicit JJA exception applies; manifest injustice is not an exception | Once a manifest injustice is declared and the court departs from the standard range, the court may suspend the disposition and impose alternatives | The court lacks authority to suspend a manifest-injustice disposition absent a statutory exception; reversal and remand for new disposition hearing |
| Whether declaring manifest injustice allows suspension power beyond JJA limits | Manifest injustice does not expand statutory suspension authority | Manifest injustice frees the court from JJA sentencing scheme, permitting suspension | Declaring manifest injustice governs length but does not confer power to suspend when statute forbids it |
Key Cases Cited
- State v. A.S., 116 Wn. App. 309 (Court of Appeals 2003) (juvenile court may not suspend disposition absent statutory exception)
- State v. Crabtree, 116 Wn. App. 536 (Court of Appeals 2003) (held manifest-injustice declaration permitted suspension and alternative disposition)
- State v. Clark, 91 Wn. App. 581 (Court of Appeals 1998) (courts lack inherent authority to suspend sentences; must follow statute)
- State v. M.L., 134 Wn.2d 657 (Washington Supreme Court 1998) (juvenile courts have broad discretion to determine disposition length)