State of Washington v. Lorenzo Alex Campos, 34175-5

Campos (age 19) violated a two‑year no‑contact protection order with Dominguez and was convicted by a jury of one felony protection order violation, witness tampering, and three gross misdemeanor protection‑order violations based on in‑jail phone calls to the victim.
At sentencing the State calculated Campos’ standard range at 60 months; Campos requested an exceptional downward sentence to 24 months plus 12 months community custody, citing youth, immaturity, and the victim’s purported willing participation in the altercation.
The trial court stated it read the presentence report, heard argument, and imposed concurrent sentences including 60 months for the felony and ordered 12 months of community custody.
Campos appealed, arguing the court failed to meaningfully consider youth as a mitigating factor to justify an exceptional downward sentence and that the imposed community custody caused his term to exceed the statutory maximum.
The Court of Appeals affirmed the standard‑range sentence (finding no categorical refusal to consider an exceptional sentence) but accepted the State’s concession that the added community custody caused the total confinement to exceed the statutory maximum and remanded to strike community custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court failed to meaningfully consider youth as mitigation for an exceptional downward sentence	Campos: court ignored youth/immaturity and failed to meaningfully consider exceptional downward sentence	State: court considered the request (read report, heard argument) and declined within discretion	Court: No reversible error — court did not categorically refuse to consider an exceptional sentence and implicitly denied the request by imposing a standard‑range sentence
Whether imposition of 12 months community custody improperly made the total exceed statutory maximum for the felony	Campos: 12 months community custody included in judgment	State: conceded error	Court: Remanded to strike community custody because incarceration plus community custody exceeded the 60‑month statutory maximum

State v. Ammons, 105 Wn.2d 175 (sentence within standard range not appealable)
State v. Grayson, 154 Wn.2d 333 (trial court must consider statutorily authorized alternatives and cannot categorically refuse)
State v. Knight, 176 Wn. App. 936 (procedural aspects of sentencing review)
State v. O'Dell, 183 Wn.2d 680 (youth can be a mitigating factor)
State v. Garcia‑Martinez, 88 Wn. App. 322 (categorical refusal and impermissible bases for denying exceptional sentences)
State v. Albright, 144 Wn. App. 566 (court may impose only statutory sentences; error where total exceeds statutory maximum)