State v. Beaver

Summary

The Washington Supreme Court held that “minimum term” and “release date” are distinct concepts under the Juvenile Justice Act. It concluded that the juvenile court, rather than the Department of Social and Health Services, has authority to set the minimum term for a manifest injustice disposition, and affirmed Beaver’s confinement until age 21.

Holdings

1. The statutory terms "minimum term" and "release date" have distinct meanings. DSHS sets the juvenile's release or discharge date, while a minimum term must already exist before that date is set.
2. For a manifest injustice disposition, the juvenile court, not DSHS, has authority to set the minimum term, subject to the limitations in RCW 13.40.030(2). DSHS retains authority to set the release date.
3. RCW 13.40.030(2) does not prohibit the juvenile court from setting the minimum term at 100 percent of the maximum term for a manifest injustice disposition.

Questions Presented

1. Whether the terms "minimum term" and "release date" are distinct under the Juvenile Justice Act of 1977.
2. Whether the Department of Social and Health Services has exclusive authority to set the minimum term for a juvenile receiving a manifest injustice disposition.
3. Whether a juvenile court may set the minimum term equal to the maximum term for a manifest injustice disposition.

Disposition

reversed