Watson v. State
2017 Alas. App. LEXIS 83
| Alaska Ct. App. | 2017Background
- Elizabeth Watson, age 14, was charged with DUI (misdemeanor) and tried and convicted in district court under AS 47.12.030(b), which requires minors charged with non-felony traffic offenses to be prosecuted as adults.
- Watson appealed, arguing the statute violated her rights to equal protection and due process under the Alaska Constitution by denying juvenile-court rehabilitation procedures.
- The court applied Alaska’s three-part “sliding-scale” equal protection test: (1) importance of the individual interest, (2) importance of the government interest, and (3) means-to-end fit.
- The court relied on precedent (Gray v. State) recognizing that juveniles have no constitutional right to juvenile-court adjudication and that the interest is limited to minimizing punishment.
- The State argued the legislature has a legitimate interest in regulating driving — a dangerous adult activity — and can require adult prosecution to promote public safety and accountability.
- The court rejected both equal protection and due process challenges, concluding AS 47.12.030(b) is neither arbitrary nor discriminatory and that Watson was not entitled to an amenability hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Equal protection: Does mandatory adult prosecution for minors who commit misdemeanor traffic offenses violate equal protection? | Watson: Minors who commit traffic misdemeanors are as amenable to rehabilitation as other juvenile offenders; treating them as adults is "uniquely harsh" and discriminates against them. | State: Legislature has a strong public-safety interest in regulating driving; minors pose special risks and can be held to adult standards for traffic offenses. | Court: Statute is rationally related to legitimate government interests; classification is not arbitrary or discriminatory — equal protection claim denied. |
| Due process: Was Watson entitled to an evidentiary hearing on amenability to juvenile rehabilitation? | Watson: Due process required a hearing so she could show amenability to juvenile treatment. | State: No due-process right to such a hearing because the statute validly mandates adult prosecution. | Court: Because the statute is constitutional, there is no entitlement to an amenability hearing — due process claim denied. |
Key Cases Cited
- Gray v. State, 267 P.3d 667 (Alaska App. 2011) (juveniles have no constitutional right to juvenile-court trial; interest limited to minimizing punishment)
- W.M.F. v. State, 723 P.2d 1298 (Alaska App. 1986) (discussing juvenile interest in juvenile adjudication)
- State v. Ladd, 951 P.2d 1220 (Alaska App. 1998) (legislature may draw distinctions among minors if not arbitrary or discriminatory)
- Anderson v. State, 904 P.2d 433 (Alaska App. 1995) (recognizing legislature’s authority to establish penalties and classifications)
- Ardinger v. Hummel, 982 P.2d 727 (Alaska 1999) (holding minor drivers are held to an adult standard of care for public safety)