State v. Saenz

Summary

The Washington Supreme Court held that Jorge Saenz’s 2001 adult-court conviction could not be used as a strike under the Persistent Offender Accountability Act. The court found that Saenz’s waiver of juvenile-court jurisdiction was not intelligently made and that the juvenile court failed to enter the required best-interest findings before transferring the case. The court reversed the Court of Appeals and affirmed Saenz’s 561-month sentence.

Holdings

1. Saenz's waiver was invalid because the record did not demonstrate that it was intelligently made or that he was fully informed of the right being waived and the consequences of leaving the juvenile justice system.
2. A juvenile court may not validly transfer a case to adult court without independently determining and entering written findings that declining juvenile jurisdiction is in the best interest of the juvenile or the public, even when the parties waive the decline hearing and stipulate to transfer.
3. Saenz's 2001 adult-court conviction could not be used as a strike under the POAA because the State could not establish that he was properly transferred to adult court.

Questions Presented

1. Whether Saenz knowingly and intelligently waived juvenile court jurisdiction and the decline hearing as required by RCW 13.40.140(9).
2. Whether the juvenile court validly transferred Saenz's case to adult court without a decline hearing and without written findings that transfer was in the best interest of the juvenile or the public.
3. Whether Saenz's resulting adult-court conviction could be counted as a strike under the POAA.

Disposition

reversed