State Of Washington v. Ricky Deshawn King, 75306-1

Background

In 2015 Ricky DeShawn King pleaded guilty to first‑degree child molestation; the court imposed a 96‑month‑to‑life sentence suspended under the Special Sex Offender Sentencing Alternative (SSOSA) with conditions including five years of sex‑offender treatment, no contact with the victim or other minors, polygraph/UA testing, and reporting address/romantic relationships to DOC/CCO.
A January 2016 review revealed King stopped attending group treatment in October 2015 and was seen leaving court with an adult female and a child; DOC filed a Notice of Violation alleging, among other things, unapproved contact with minors and failure to report a romantic relationship.
King admitted multiple violations at a February 2016 hearing; the court found violations but did not revoke the SSOSA then.
From March–April 2016 DOC alleged additional violations (contact with the victim and minors, failing to report before a polygraph, leaving DOC without permission, failure to report address, termination from treatment); police arrested King outside the victim’s residence.
At the May 3, 2016 revocation hearing King admitted several violations (contact with minors, failing to report before polygraph, missing UA, leaving DOC without permission, being at the victim’s residence, termination from treatment) but denied direct contact with the named victim and denied failing to report his address; the court relied on treatment‑provider letters, DOC reports, and King’s own admissions and revoked the SSOSA.

Issues

Issue	King's Argument	State/DOC's Argument	Held
Whether revocation violated due process/right to confrontation by relying on evidence King contacted the victim (A.W.H.).	King contends the court relied on hearsay and his polygraph statements about possible contact without adequate confrontation, violating due process.	The State contends the court could consider King’s own statements, treatment‑provider reports, and other evidence; confrontation rights are limited in revocation proceedings.	Court held no due process violation: King’s admissions and other records supported the finding of contact.
Whether revocation violated due process by finding King failed to report his address.	King denied failing to report address.	State relied on DOC reports, defense counsel’s admissions that King spent time at his father’s house and received mail there.	Court held sufficient evidence existed to find King failed to report his address.
Whether the court had authority to revoke SSOSA based on failure to make reasonable progress in treatment.	King argued procedural protections were not honored for some allegations.	State noted the undisputed record showed lack of engagement and termination from treatment, which alone permits revocation.	Court held revocation was authorized because King failed to make reasonable progress and was terminated from treatment.
Standard of review for SSOSA revocation.	N/A (framework for challenge).	N/A.	Court applied abuse‑of‑discretion review and found no abuse.

Key Cases Cited

Morrissey v. Brewer, 408 U.S. 471 (establishes minimal due process rights in parole/probation revocation)
State v. Dahl, 139 Wn.2d 678 (explains limited confrontation and hearsay rules in revocation proceedings)
State v. Badger, 64 Wn. App. 904 (standard of review for SSOSA revocation)
State v. Partee, 141 Wn. App. 355 (abuse of discretion framework)
State v. Miller, 180 Wn. App. 413 (statutory authority to revoke SSOSA for violation or lack of treatment progress)