State of Washington v. R.C., 32956-9

Juvenile R.C., age 10 years 7 months, was charged with one count of second-degree assault and two counts of fourth-degree assault for incidents in September 2014 involving his great-aunt, mother, and aunt.
Washington law presumes children 8–12 lack capacity to commit crimes unless rebutted by clear and convincing evidence that they understood the acts and knew they were wrong (RCW 9A.04.050).
A capacity hearing relied on testimony from a juvenile probation officer (Steven Driscoll), police reports, and family statements about prior assaults, prior law-enforcement involvement (including diversion in Montana), diagnoses (PTSD, ODD), medication, and counseling.
The trial court found the presumption rebutted and adjudicated R.C. guilty on all counts; he received time-served detention on two fourth-degree counts and commitment to juvenile rehabilitation for 15–36 weeks on the second-degree count.
On appeal R.C. argued (1) the State failed to overcome the capacity presumption and (2) trial counsel was ineffective for not asserting self-defense.

Issue	Plaintiff's Argument (State)	Defendant's Argument (R.C.)	Held
Whether the State overcame the statutory presumption that a child 8–12 lacks capacity to commit the charged crimes	The State argued there was clear and convincing, substantial evidence across the seven-factor J.P.S. framework (nature of crime, age/maturity, secrecy, admonitions not to tell, prior conduct, consequences, acknowledgment) to show R.C. understood the acts and that they were wrong	R.C. argued his youth, history of abuse, mental-health diagnoses, impulsivity, and susceptibility to outside pressures meant he lacked capacity; amici urged juvenile developmental science should alter inquiry	Court affirmed: substantial clear and convincing evidence supported capacity under the seven-factor test; prior similar conduct and prior law-enforcement consequences were especially persuasive
Whether counsel rendered ineffective assistance by failing to assert self-defense	State/record: counsel reasonably pursued mitigation and a theory that raising but not thrusting a knife might not constitute assault; counsel anticipated the court would reject self-defense given the evidence	R.C. argued counsel should have argued self-defense because family members allegedly behaved in ways that could have made him fear imminent harm	Court affirmed: counsel's choice was a legitimate trial strategy and not deficient under Strickland; no deficient performance shown, so ineffective assistance claim fails

State v. Q.D., 102 Wn.2d 19 (1984) (explains purpose of capacity presumption and relevance of juvenile understanding)
J.P.S. v. State, 135 Wn.2d 34 (1998) (sets seven-factor framework and requires clear and convincing proof that child knew act was wrong)
State v. Ramer, 151 Wn.2d 106 (2004) (clarifies that moral guilt alone is insufficient; focuses on knowledge of wrongfulness)
State v. Linares, 75 Wn. App. 404 (1994) (discusses nature-of-crime factor and age relevance)
State v. Hill, 123 Wn.2d 641 (1994) (defines substantial evidence standard)
Strickland v. Washington, 466 U.S. 668 (1984) (establishes two-prong test for ineffective assistance: deficiency and prejudice)
State v. Grier, 171 Wn.2d 17 (2011) (applies Strickland presumption and strategic-decision deference in Washington)
State v. Maurer, 34 Wn. App. 573 (1983) (discusses assault via conduct creating reasonable apprehension and when weapon display constitutes violence begun)