State v. Harris, 559 P.3d 499

Background

Darren Harris was 17 when he committed a fatal stabbing and robbery in 2011, leading to charges of first-degree murder with a deadly weapon.
After plea negotiations, Harris pleaded guilty to second-degree murder and first-degree robbery; he and the State jointly recommended a total sentence of 244 months.
The trial court accepted the plea and the recommended sentence, emphasizing the negotiated nature of the plea.
After Houston-Sconiers was decided, requiring courts to consider the mitigating characteristics of youth at sentencing, Harris sought resentencing, arguing the court did not consider his youth.
The Court of Appeals acknowledged a Houston-Sconiers error but ruled that resentencing was not the appropriate remedy given the plea agreement, instead granting Harris the right to withdraw his plea.
The Washington Supreme Court accepted review to clarify the requirements of Houston-Sconiers in the context of binding plea agreements with joint sentence recommendations.

Issues

Issue	Harris’s Argument	State’s Argument	Held
Does Houston-Sconiers require trial courts to consider youth for juveniles sentenced under plea agreements with joint recommendations?	Harris: Courts must always consider mitigating qualities of youth, even if parties agree not to advocate for a lesser sentence.	State: Once a plea agreement is accepted and followed, the court is not required to independently consider youth if not argued.	No, not when the plea bargain is accepted and parties agreed not to advocate for less; no sua sponte inquiry required.
If there is a Houston-Sconiers violation in this context, what is the remedy?	Harris: Entitled to resentencing so court can consider mitigating evidence of youth.	State: Remedy is not resentencing; at most, Harris could withdraw his plea.	Resentencing is the correct remedy for a Houston-Sconiers violation, but no violation occurred here.
Can retroactive rules expand the scope of plea agreements?	Harris: Plea agreements must reflect retroactive changes in law, and courts should apply new rules.	State: Plea agreements are binding unless legislative intent or law expressly states otherwise; Houston-Sconiers did not intend to modify prior plea agreements.	Houston-Sconiers does not require modifications to binding plea agreements; decision does not address prior plea bargains.
May the parties be released from the plea agreement if Houston-Sconiers applies?	Harris: If he cannot present mitigating evidence, both parties should be released from the sentence recommendation.	State: Parties should be held to the original bargain unless the agreement is breached.	No relief from plea agreement is warranted where parties received the benefit of the bargain.

Key Cases Cited

State v. Houston-Sconiers, 188 Wn.2d 1 (Wash. 2017) (trial courts must consider mitigating qualities of youth and retain discretion to sentence below standard ranges for juveniles)
In re Pers. Restraint of Ali, 196 Wn.2d 220 (Wash. 2020) (Houston-Sconiers is a substantive and retroactive constitutional rule)
State v. Sledge, 133 Wn.2d 828 (Wash. 1997) (plea agreements are contracts involving fundamental rights and good faith obligations)
State v. Hunsicker, 129 Wn.2d 554 (Wash. 1996) (once a plea agreement is accepted by a court, it is binding between the parties)
State v. Ramos, 187 Wn.2d 420 (Wash. 2017) (the burden of proving mitigating factors for a downward sentence lies with the defendant)