State of Washington v. Guillermo Adam Ledezma, 34005-8

Background

In December 2015, 16‑year‑old Guillermo Adam Ledesma burglarized his sister Alicia Ortega’s home while the family attended a Christmas pageant; the Ortegas discovered him inside with their property. Alicia was pregnant and the family later relocated out of safety concerns.
Ledesma had an escalating juvenile record (theft, malicious mischief) and was on probation for a June 2015 disposition with multiple probation violations and a recent 15‑day confinement; he had gang involvement and substance‑use and mental‑health issues.
At disposition the State sought an upward (manifest injustice) commitment; probation recommended 21–28 weeks at a Juvenile Rehabilitation Administration (JRA) facility; the State recommended 12–16 weeks; defense requested standard range local sanctions (≤30 days).
The juvenile court found a manifest injustice if confined to the standard range, citing victim vulnerability, recent criminal history/probation violations, that the standard range was too lenient, and that local probation lacked sufficient structure; it imposed 21–28 weeks in a JRA facility.
On appeal Ledesma challenged (1) whether the court adequately placed findings on the record, (2) sufficiency/clear‑and‑convincing support for the findings and for manifest injustice, (3) the labeling of the Ortegas as “particularly vulnerable” victims, and (4) whether the 21–28 week term was excessive.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Ledesma)	Held
Whether the juvenile court sufficiently placed findings on the record per JuCR 7.12(e)	Record testimony and the court’s oral ruling and written order satisfy JuCR 7.12(e)	Court failed to patently place findings on the record	Held for State — requirement satisfied (oral ruling incorporated into written order; testimony was material)
Whether substantial evidence and clear‑and‑convincing evidence support a manifest‑injustice departure from the standard range	Probation testimony and victim testimony show escalating criminality, lack of remorse, failed supervision, substance/mental‑health needs, and need for secure structured care — supports departure	Insufficient evidence; reliance on speculation about need for structure and absence of detailed treatment plan	Held for State — substantial and clear‑and‑convincing evidence (except vulnerability finding) support departure
Whether the Ortegas were “particularly vulnerable” victims	The court treated family relationship and Alicia’s pregnancy as vulnerability factors	Ledesma argued insufficient evidence that pregnancy or victim vulnerability materially enabled the burglary; prior burglaries occurred when she wasn’t pregnant	Held partially for Ledesma — appellate court strikes the particular‑vulnerability finding as unsupported for Agustin and finds Alicia’s pregnancy did not show required vulnerability/special susceptibility; but this error was not outcome‑determinative
Whether the 21–28 week JRA commitment is excessive	JRA term recommended by probation; record shows need for secure, structured, rehabilitative placement beyond local sanctions	Term is excessive relative to standard range (≤30 days)	Held for State — 21–28 weeks not clearly excessive; within trial court’s broad discretion given valid aggravating factors (probation history, public danger, need for secure treatment)

Key Cases Cited

State v. Crabtree, 116 Wn. App. 536 (discussion of juvenile disposition grid)
State v. Duncan, 90 Wn. App. 808 (juvenile manifest‑injustice standard; appellate review)
State v. JN, 64 Wn. App. 112 (need for substantial record support for departure reasons)
State v. Smith, 185 Wn. App. 945 (standard for substantial evidence review)
State v. Ogden, 102 Wn. App. 357 (structured detention can itself be treatment; burden on State to propose plan)
State v. Wood, 57 Wn. App. 792 (egregious lack of remorse and sophistication as aggravating factors)
State v. Vermillion, 66 Wn. App. 332 (sophistication/planning supporting exceptional sentence)
State v. K.E., 97 Wn. App. 273 (appellate affirmance may rest on subset of valid aggravating factors)
State v. Bourgeois, 72 Wn. App. 650 (remand required when court placed significant weight on improper factors)