State of Washington v. Steven Ruiz Sibaja, 33838-0

Steven Ruiz-Sibaja received a SSOSA after pleading guilty to first-degree child rape, with conditions including no pornography and no alcohol.
During a polygraph he admitted receiving and viewing nude photos from a 21-year-old and admitted consuming wine (small amounts at church and Christmas).
Treatment providers and a corrections officer reported limited progress and questioned his honesty, recommending revocation.
The trial court found Ruiz-Sibaja violated both the pornography and alcohol conditions and revoked his SSOSA; a written revocation followed.
On appeal, the parties agreed the pornography-condition basis was unconstitutionally vague; the State argued the alcohol violation alone sufficed for revocation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether revocation of SSOSA was an abuse of discretion given one invalid ground (pornography prohibition)	Ruiz-Sibaja: Revocation improper because one of the two stated bases was unconstitutionally vague, so revocation cannot stand absent reliance solely on a valid ground	State: Even removing the pornography basis, the alcohol violation (and limited treatment progress) independently justified revocation	Reversed and remanded: because the trial court relied on both grounds with no indication it would have revoked based on the alcohol violation alone, remand for a new revocation hearing is required

State v. Dahl, 139 Wn.2d 678 (1999) (SSOSA revocation standards)
State v. Kuhn, 81 Wn.2d 648 (1972) (standard for abuse of discretion in revocation)
State ex rel. Carroll v. Junker, 79 Wn.2d 12 (1970) (discretion abused when based on untenable grounds)
State v. Sansone, 127 Wn. App. 630 (2005) (pornography/sexual-conduct condition vagueness)
State v. Gaines, 122 Wn.2d 502 (1993) (remand required when sentencing/revocation rests on multiple grounds and some are invalid)