State v. D.L.
Fourteen-year-old D.L. entered a plea agreement believing he was subject to a standard range sentence. Subsequently, under Washington’s Manifest Injustice provision of the Juvenile Code, the court imposed a longer sentence on D.L. based on aggravating factors that he had no notice of at the time he made his agreement—facts alleged by a probation officer months after D.L. entered his guilty plea.
Juvenile Law Center filed an amicus brief in the Washington Supreme Court in support of D.L. We argued that the Fourteenth Amendment due process guarantees requires juvenile offenders receive notice of the aggravating factors a court may rely on to impose a manifest injustice sentence before the entry of a guilty plea or agreeing to a deferred disposition. We further argued that providing youth with constitutionally sufficient notice does not run counter to the rehabilitative goals of the juvenile justice system.
The Washington Supreme Court held that youth are deprived of due process and fundamental fairness when a court imposes a manifest injustice disposition based on facts that the youth did not have notice of at the time of their plea. In a concurring opinion, Chief Justice González emphasized the influence of racial bias on decisions to impose manifest injustice sentences, writing that “the fact that children of color systematically receive disproportionately high sentences violates the promise of due process and equal protection of the law. . . . Given what we know about disproportionate outcomes for people of color in our legal system, we must take steps to ensure that all juveniles have meaningful notice and opportunity to defend against allegations that expose them to a higher sentence.”