365 P.3d 177
Wash. Ct. App.2015Background
- Defendants Zyion Houston‑Sconiers (17 at offense) and Treson Roberts (16) were charged with multiple first‑degree robberies and related offenses; adult court acquired jurisdiction under Washington’s automatic‑decline statute, RCW 13.04.030.
- Juries convicted both; special findings that each was armed with a firearm on multiple counts triggered mandatory firearm‑enhancement terms under RCW 9.94A.533.
- Trial court imposed exceptional (downward) base sentences of zero months for the underlying counts but was required to impose the mandatory consecutive firearm enhancements: 372 months for Houston‑Sconiers and 312 months for Roberts.
- Defendants challenged the constitutionality of the automatic‑decline statute and mandatory enhancements under the Eighth Amendment and due process, relying on recent U.S. Supreme Court juvenile sentencing precedents.
- The majority held the automatic‑decline statute did not violate the Eighth Amendment or due process given existing precedent and the nature of the sentences imposed; multiple other trial‑level claims (confrontation, sufficiency, prosecutorial misconduct, LFO inquiry) were rejected in the unpublished portion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RCW 13.04.030’s automatic decline (mandatory transfer of 16–17‑year‑olds for certain crimes) violates the Eighth Amendment | Automatic decline treats juveniles as adults without individualized consideration of youth; Roper/Graham/Miller require individualized youth consideration | Statute is presumptively constitutional; Roper/Graham/Miller restrict only death and LWOP contexts and do not outlaw automatic transfer for older juveniles | Court: statute does not violate Eighth Amendment or due process in these circumstances; defendants failed to show adult jurisdiction itself is punishment |
| Whether Miller/Graham/Roper undermine In re Boot (which upheld automatic decline) | Boot is outdated after modern juvenile sentencing jurisprudence and neuroscience; mandatory decline forecloses individualized sentencing | Boot’s analysis remains partially valid; new cases limit relief to most severe penalties and do not automatically invalidate transfer statutes | Court: Boot’s core holding still controls for non‑LWOP/death contexts; defendants’ sentences not cruel or unusual |
| Whether mandatory firearm enhancements rendered sentences grossly disproportionate for juveniles | Enhancements produced decades‑long mandatory terms that effectively forfeit youths’ formative years, requiring individualized consideration | Enhancements are statutory; trial court could and did impose exceptional downward base terms; Eighth Amendment prohibitions in Roper/Graham/Miller are narrow | Court: enhancements did not constitute Eighth Amendment violation here; overall sentences were below the most severe punishments addressed by the Supreme Court |
| Whether trial errors (confrontation, sufficiency, prosecutorial misconduct, LFOs) require reversal | Multiple trial rulings deprived fair trial and sentencing (confrontation clause, insufficient evidence on assaults and enhancements, misconduct, LFOs without ability‑to‑pay inquiry) | Trial rulings were correct; statement admitted was nontestimonial; evidence supported convictions and enhancements; court made individualized LFO inquiries; no prejudicial misconduct | Court: rejected defendants’ claims; trial court rulings affirmed; PRP by Houston‑Sconiers denied |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (prohibits death penalty for crimes committed as juveniles and identifies youth‑related differences relevant to Eighth Amendment analysis)
- Graham v. Florida, 560 U.S. 48 (bars life without parole for non‑homicide juvenile offenders; treats certain juvenile life terms analogously to capital punishment)
- Miller v. Alabama, 567 U.S. 460 (prohibits mandatory life without parole for juveniles; requires individualized sentencing consideration of youth)
- In re Boot, 130 Wn.2d 553 (Wash. Sup. Ct. upheld automatic‑decline statute against federal constitutional challenge)
- State v. O’Dell, 183 Wn.2d 680 (recognizes adolescent brain research and its relevance to juvenile sentencing considerations)
- State v. Massey, 60 Wn. App. 131 (earlier Washington appellate decision rejecting an Eighth Amendment challenge that treated age as irrelevant to proportionality)