State of Washington v. Michael Riley Frazier, 33568-2

In December 2014, then-15-year-old Michael R. Frazier and Mary Bartholomew (pseudonym) met at a Fire Hall; Frazier later asked Mary to drive to a closed store parking lot.
While alone in Mary’s car, Frazier pinned Mary against the door, touched her breasts and genital area despite her saying “no,” pushing, kicking, and crying; she sustained bite marks and bruises.
Mary reported the incident after the holidays; Frazier admitted Mary said “no” several times and later told a friend he felt bad about his actions.
The State charged Frazier in juvenile court with indecent liberties by forcible compulsion (RCW 9A.44.100(1)).
At a bench trial the juvenile court found Mary credible, concluded Frazier acted knowingly and by forcible compulsion, adjudicated him guilty, ordered juvenile detention, sex-offender registration, and a lifetime no-contact restraining order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mens rea standard	State: statutory "knowingly" applies as written; constructive knowledge uses reasonable person	Frazier: as a juvenile, court should apply a "reasonable child" standard to knowledge	Court: sufficient evidence of actual knowledge; no need to apply reasonable-child test for constructive knowledge; conviction affirmed
Right to jury trial in juvenile adjudication	State: juvenile system remains distinct; no constitutional right to jury in juvenile adjudicative stage	Frazier: juvenile proceedings have become punitive (registration, possible SVP commitment) so he is entitled to jury trial	Court: precedent controls; juveniles have no constitutional right to jury trial; decline to extend right; conviction affirmed

State v. Stribling, 164 Wn. App. 867 (court acknowledges actual vs. constructive knowledge concepts)
State v. Shipp, 93 Wn.2d 510 (discusses constructive knowledge and jury consideration of ordinary person standard)
Estes v. Hopp, 73 Wn.2d 263 (holds juveniles have no right to jury trial)
State v. Lawley, 91 Wn.2d 654 (juvenile jury-trial issue precedent)
State v. Schaaf, 109 Wn.2d 1 (juvenile adjudication and jury-trial precedent)
Monroe v. Soliz, 132 Wn.2d 414 (juvenile proceedings precedent)
State v. Chavez, 163 Wn.2d 262 (recent Supreme Court decision rejecting expansion of jury right for juveniles despite punitive characteristics)
State v. J.H., 96 Wn. App. 167 (holding sex-offender registration and related measures are regulatory, not punitive, for jury-right analysis)