State Of Washington v. Lonzo Martin Wilson, 74828-9

In 2002 Wilson pled guilty to second-degree rape of a child; court imposed a 102-month standard-range sentence suspended as a SSOSA with lifetime community custody, mandatory sex-offender treatment for three years, and no unsupervised contact with minors.
From 2002–2015 Wilson repeatedly violated SSOSA terms (failure to pay LFOs, failure to complete or participate in treatment, dishonest reporting of relationships and residence) and had numerous modification hearings.
In 2012 DOC discovered Wilson had fathered two children and had direct contact with them since 2005; the court ordered 180 days confinement and renewed treatment requirements but left SSOSA intact.
In early 2015 Wilson failed to report and tested positive for methamphetamine; he admitted the violations, was given another short confinement period and ordered into treatment, with a warning that further drug use or child contact would prompt revocation.
In May 2015 Wilson again tested positive for methamphetamine and admitted unapproved contact with his minor children; the State moved to revoke his SSOSA and the trial court granted revocation.
The court weighed victim and public safety against Wilson’s interests, heard expert testimony favorable to Wilson, but found repeated dishonesty, drug use, and failure to complete treatment made him a risk and reached a “tipping point.”

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by revoking Wilson's SSOSA without adequately considering alternatives	Wilson: court failed to consider alternatives before revocation and therefore abused its discretion	State: court properly considered evidence and alternatives, and revocation was justified because violations endangered public safety	Court: No abuse of discretion; trial court considered alternatives and permissibly revoked SSOSA given repeated violations and threat to safety

State v. Miller, 159 Wn. App. 911 (2011) (SSOSA may be revoked where sufficient proof shows violation or failure in treatment)
State v. Miller, 180 Wn. App. 413 (2014) (when violation threatens public safety, court need not probe reasons for violation)
State v. McCormick, 166 Wn.2d 689 (2009) (standard for SSOSA eligibility and review; abuse-of-discretion framework)
State v. Partee, 141 Wn. App. 355 (2007) (review of revocation decisions is for abuse of discretion)