State Of Washington, V. J.t.w., 81549-1

April 9, 2020: J.T.W., his brother, and others met to buy/trade firearms; an encounter with Smith and Wight turned violent and gunfire erupted. J.T.W.’s brother was killed; Wight was shot in the legs.
State charged J.T.W. with second degree assault (for Wight’s injuries).
J.T.W. entered an Alford plea; he requested a standard-range juvenile disposition and the State/probation recommended standard range.
The court imposed a standard-range disposition of 103–129 weeks confinement.
On appeal J.T.W. argued the juvenile court erred by failing to consider the mitigating factor of “strong and immediate provocation” (RCW 13.40.150(h)(ii)) tied to his brother’s death and that Houston‑Sconiers youth-based mitigation principles should apply.
Record included the brother’s death (affidavit relied on for the Alford plea) and the court expressed sympathy at disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court erred by failing to consider mitigating factor of "strong and immediate provocation" (and youth-based mitigation) before imposing a standard-range disposition	J.T.W.: court failed to consider provocation from brother’s death and should apply youth-mitigation principles from Houston‑Sconiers	State: no requirement for the judge to expressly state consideration of mitigating factors absent counsel’s request; courts need not explain reasoning for a standard-range disposition; Houston‑Sconiers applies only to juveniles sentenced in adult court	Court affirmed: no error. Because defense did not request mitigation or a below-range disposition, no express on-the-record statement was required; standard-range disposition presumed adequate; Houston‑Sconiers does not apply to juvenile-court dispositions.

State v. McGill, 112 Wn. App. 95 (2002) (standard-range juvenile dispositions generally not appealable)
State v. McFarland, 189 Wn.2d 47 (2017) (appellate review of legal determinations underlying sentencing still permitted)
State v. B.O.J., 194 Wn.2d 314 (2019) (standard for manifest abuse of discretion when declining manifest-injustice departure)
State v. N.E., 70 Wn. App. 602 (1993) (no requirement for judge to expressly state consideration of mitigating factors absent counsel argument)
State v. Strong, 23 Wn. App. 789 (1979) (no need to make record of reasoning for standard-range juvenile disposition; must state reasons when departing range)
State v. M.L., 134 Wn.2d 657 (1998) (sentence is excessive only when unjustifiable under any reasonable view of the record)
State v. Tai N., 127 Wn. App. 733 (2005) (standard-range disposition normally adequate to achieve JJA goals)
State v. Houston‑Sconiers, 188 Wn.2d 1 (2017) (Eighth Amendment duty to consider youth in adult sentencing; discretionary downward departures)
State v. S.D.H., 17 Wn. App. 2d 123 (2021) (Houston‑Sconiers does not extend to juvenile-court dispositions)