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State v. Houston-Sconiers

Washington Supreme Court
391 P.3d 409, 188 Wash. 2d 1 (2017)
ELI5:

Rule of Law:

The Eighth Amendment to the U.S. Constitution requires sentencing courts to have complete discretion to depart from standard sentencing ranges and mandatory enhancements when sentencing a juvenile offender in adult court. The court must consider the mitigating qualities of youth, such as immaturity and capacity for change.


Facts:

  • On Halloween night in 2012, Zyion Houston-Sconiers, age 17, and Treson Roberts, age 16, met with friends, drank vodka, and smoked marijuana.
  • A witness saw Houston-Sconiers holding a silver revolver and a white 'Jason' style hockey mask.
  • Houston-Sconiers, Roberts, and a third boy approached two brothers, Andrew Donnelly (19) and S.D. (13), and robbed them of their candy and a red devil mask at gunpoint while one wore the Jason mask.
  • Later, the group approached five high school students, with one wearing the stolen devil mask and another holding a silver gun, and robbed them of their candy.
  • One of the victims from the second robbery, A.G., recognized Houston-Sconiers's voice, hid her candy, and went to a nearby house to ask for help calling the police.
  • The group then robbed a 37-year-old man, James Wright, of his cell phone at gunpoint in an apartment complex.
  • Police found the boys hiding in a broken-down Cadillac nearby.
  • A search of the Cadillac recovered the masks, candy, and a .32 caliber revolver loaded with the wrong type of ammunition.

Procedural Posture:

  • The State of Washington charged Zyion Houston-Sconiers and Treson Roberts in adult court with multiple counts, including first-degree robbery, which triggered Washington's automatic transfer statute.
  • Following a jury trial in the trial court, Houston-Sconiers was convicted of six counts of robbery and other charges with seven firearm enhancements, and Roberts was convicted of four counts of robbery and other charges with six firearm enhancements.
  • The trial court judge, stating that he lacked discretion due to mandatory sentencing laws, imposed sentences of 372 months (31 years) for Houston-Sconiers and 312 months (26 years) for Roberts, based almost entirely on consecutive firearm enhancements.
  • Houston-Sconiers and Roberts, as appellants, appealed their sentences to the Washington Court of Appeals, an intermediate appellate court.
  • A divided Court of Appeals affirmed the convictions and sentences, rejecting the appellants' Eighth Amendment claims.
  • Houston-Sconiers and Roberts, as petitioners, were granted review by the Supreme Court of Washington, the state's highest court.

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Issue:

Does the Eighth Amendment's prohibition on cruel and unusual punishment require a sentencing court in adult criminal court to have discretion to impose a sentence below the standard range and mandatory firearm enhancements for a juvenile offender, based on the mitigating qualities of youth?


Opinions:

Majority - Justice Gordon McCloud

Yes. The Eighth Amendment requires that sentencing courts have discretion to impose sentences below otherwise mandatory minimums for juvenile offenders. The U.S. Supreme Court's jurisprudence in cases like Miller v. Alabama, Graham v. Florida, and Roper v. Simmons establishes that 'children are different' and their youthfulness is a constitutionally relevant mitigating factor at sentencing. Mandatory sentencing schemes that prevent a judge from considering a juvenile's diminished culpability, immaturity, impetuosity, and capacity for rehabilitation are 'flawed.' Because the trial judge here believed he had no discretion to deviate from the mandatory firearm enhancements, which resulted in de facto life sentences of 26 and 31 years of 'flat time' for robberies committed at ages 16 and 17, the sentences are unconstitutional. Therefore, sentencing courts must have complete discretion to impose any sentence below the applicable Sentencing Reform Act (SRA) range and/or sentence enhancements after considering the mitigating qualities of youth.


Concurring - Justice Madsen

Yes, but the decision should rest on statutory grounds, not the Eighth Amendment. The court could have resolved this case by holding that Washington's Sentencing Reform Act (SRA) provides judges with the discretion to depart from mandatory firearm enhancements when imposing an exceptional sentence. The court's prior precedent in State v. Brown, which held that such enhancements were absolute, was wrongly decided and is inconsistent with the SRA's purpose to structure, not eliminate, judicial discretion. The trial court's failure to recognize its statutory discretion was an abuse of that discretion, which is sufficient grounds to remand for resentencing without needing to reach the constitutional question.



Analysis:

This decision significantly expands the constitutional protections for juveniles sentenced in Washington's adult criminal justice system. By extending the logic of the U.S. Supreme Court's Miller v. Alabama decision beyond life-without-parole sentences to long, determinate sentences created by mandatory enhancements, the court established a broad right to individualized sentencing for all juveniles. The ruling empowers trial judges to craft sentences that reflect a youth's diminished culpability and greater capacity for change, potentially leading to dramatically shorter sentences. This precedent invalidates the mandatory nature of sentencing enhancements as applied to juveniles and reinforces the principle that youth must be treated as a key mitigating factor.

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