State of Washington v. Natasha Tucker

Summary

The Washington Supreme Court held that the State failed to timely initiate proceedings to revoke Natasha Tucker's deferred disposition before the juvenile court's jurisdiction expired. A community supervision officer's report recommending that the matter later be set for revocation was not a written motion satisfying the applicable procedural requirements. The court reversed the Court of Appeals and remanded for the convictions to be vacated and the case dismissed with prejudice.

Holdings

1. A supervision officer's report that conditionally recommends setting a matter for revocation is not a written motion seeking current relief and does not institute revocation proceedings under the governing rules.
2. Because no timely revocation motion was filed before the deferred disposition period expired, the Court of Appeals' decision must be reversed and the trial court must vacate Tucker's convictions and dismiss the case with prejudice.

Questions Presented

1. Whether the juvenile court retained jurisdiction to revoke Tucker's deferred disposition when the community supervision officer filed a report recommending that the matter be set for revocation if Tucker failed to verify payment of restitution, but no written motion to revoke was filed before the supervision period expired.
2. Whether Tucker's convictions had to be vacated and the case dismissed with prejudice after the juvenile court lost jurisdiction.

Disposition

reversed_and_remanded