State Of Washington v. Mariah Lovree Knight, 75648-6

Mariah Knight was charged with possession of stolen mail and possession of methamphetamine and entered Thurston County drug court in July 2015 under a signed drug court contract.
Within a week she was sanctioned for missing two urinalyses and failing to appear at a hearing.
The State later petitioned to terminate her from drug court after multiple positive urinalyses and another failure to appear; Knight did not contest the factual allegations.
Knight requested placement in a chemical dependency program; the drug treatment program did not support that placement.
The trial court terminated Knight from the drug court program, stating she had not been participating in treatment, and convicted her on both charges.
Knight appealed, arguing the court abused its discretion by failing to analyze underlying facts before terminating her participation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court abuse its discretion by terminating Knight from drug court without discussing underlying facts?	Knight: court needed to discuss factual basis and analyze why termination was best.	State: court has discretion and oral ruling showed nonparticipation; no detailed findings required.	No abuse of discretion; termination affirmed because Knight failed to participate and did not dispute violations.
What standard governs termination from drug court?	Knight: (implicit) termination requires factual consideration and proper analysis.	State: termination decided under the court’s discretionary authority analogous to probation violations.	Court applies discretionary review; State must prove noncompliance by preponderance.
Must the court make detailed findings when terminating a participant?	Knight: detailed findings or factual analysis required.	State: no statutory or caselaw requirement for detailed findings; oral explanation suffices.	No detailed findings required; oral statement that participant was not participating was adequate.
Should appellate costs be imposed if the State substantially prevails?	Knight: requests no appellate costs due to indigence.	State: did not oppose.	Court declines to impose appellate costs given Knight’s indigence.

State v. Cassill-Skilton, 122 Wn. App. 652 (discusses notice/hearing requirement before terminating drug court participation)
State v. Varnell, 137 Wn. App. 925 (State must prove noncompliance by a preponderance)
State v. Kuhn, 81 Wn.2d 648 (discretionary nature of revocation/related decisions)
State v. Badger, 64 Wn. App. 904 (suspended sentence revocation left to court discretion)
State v. J.A., 105 Wn. App. 879 (deferred disposition compliance decisions are discretionary)
State v. Neal, 144 Wn.2d 600 (abuse of discretion standard defined)
State v. Sinclair, 192 Wn. App. 380 (court may decline appellate costs; ability to pay is a factor)