State Of Washington v. M.B., Jr., 48125-1

17-year-old M.B. lived with his mother and her boyfriend, Daniel Bowers; a house rule forbade girls in M.B.’s room.
Around 4:30 a.m., Bowers found M.B. with a girl in his bedroom, used profane language, and woke M.B.’s mother; a heated verbal confrontation followed.
Bowers approached chest-to-chest; M.B. struck Bowers twice in the head; Bowers left and called police; M.B. later told an officer he hit Bowers to defend himself.
M.B. was charged with fourth-degree assault in juvenile court; he claimed self-defense at the adjudicatory hearing.
The juvenile court excluded self-defense, finding M.B. lacked an objective fear of imminent injury and convicted him.
The Court of Appeals reversed, holding the record contained sufficient evidence to let M.B. raise self-defense and that the exclusion prejudiced him.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court erred in refusing to allow self-defense claim	State: M.B. lacked objective fear; evidence insufficient to raise self-defense	M.B.: testimony and circumstances supported subjective belief of imminent harm and that belief was objectively reasonable	Reversed: court erred; sufficient evidence existed to raise self-defense and exclusion was prejudicial

State v. Echeverria, 85 Wn. App. 777 (discussion of juvenile findings and written decision requirements)
State v. Levy, 156 Wn.2d 709 (unchallenged findings are verities on appeal)
State v. Mendez, 137 Wn.2d 208 (definition of substantial evidence)
State v. Kintz, 169 Wn.2d 537 (respondent admits truth of State's evidence when challenging sufficiency)
State v. Thomas, 150 Wn.2d 821 (deference to trier of fact on credibility)
State v. Tyler, 138 Wn. App. 120 (elements of fourth-degree assault)
State v. McCullum, 98 Wn.2d 484 (self-defense as affirmative defense; burden shifting)
State v. Graves, 97 Wn. App. 55 (some evidence from any source suffices to raise self-defense; subjective and objective elements)
State v. Summers, 120 Wn.2d 801 (same rule that minimal evidence raises self-defense issue)
State v. Walden, 131 Wn.2d 469 (self-defense requires subjective belief and objective reasonableness)
State v. Read, 147 Wn.2d 238 (standard of review depends on basis for refusing to consider self-defense)
State v. B.J.S., 140 Wn. App. 91 (findings must support conclusions of law)
State v. Werner, 170 Wn.2d 333 (excluding a supported defense is reversible when prejudicial)