State Of Washington v. Robert Samuel Jacobs, 73712-1

Robert Jacobs pleaded Alford to two counts of first-degree child molestation for repeatedly abusing his girlfriend’s 7-year-old daughter while living in the home.
Jacobs has four biological children who live with their mother; the youngest was seven at sentencing. Jacobs sought contact with his children.
Plea agreement: State recommended lifetime ban on contact with the victim and a ban on contact with any minors without supervision by a responsible adult aware of the conviction.
At sentencing the court imposed concurrent 72 months-to-life terms and community custody conditions requiring a sexual deviancy evaluation and lifetime prohibition stated in the judgment: "no direct and/or indirect contact with minors."
The trial court’s oral remarks suggested it lacked sufficient information to decide whether Jacobs could have future contact with his biological children and indicated evaluation results might permit contact; the written judgment, however, appears to prohibit all contact unconditionally.
The Court of Appeals remanded for clarification because of ambiguity whether the no-contact prohibition as to Jacobs’ biological minor children was intended to be unconditional or contingent on evaluations/approvals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the lifetime, unconditional prohibition on direct and indirect contact with minors (including Jacobs’ biological children) was an appropriate crime-related prohibition.	The State argued the court may impose no-contact and crime-related prohibitions to protect minors and follow the plea recommendation.	Jacobs argued the unconditional lifetime ban as written unreasonably deprived him of parental rights because the court lacked sufficient information and the ban barred even supervised contact or conditional approval.	The court held the written condition as applied to Jacobs’ biological children, without explanation or link to evaluations/treatment, was unreasonable or at least ambiguous, and remanded for clarification.

North Carolina v. Alford, 400 U.S. 25 (recognizes Alford plea concept)
In re Personal Restraint of Rainey, 168 Wn.2d 367 (crime-related prohibitions must be sensitively imposed and are fact-specific)
State v. Berg, 147 Wn. App. 930 (upheld unsupervised-contact prohibition tailored to protect children in the home after parental abuse)
State v. Corbett, 158 Wn. App. 576 (upheld contact restrictions tied to treatment and supervisory approval where offender abused parental role)
In re Welfare of Sumey, 94 Wn.2d 757 (parens patriae permits state intervention when parental actions harm child)
State v. Warren, 165 Wn.2d 17 (conditions limiting parental rights must be reasonably necessary to protect children)