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State v. Cofield

Court of Appeals of Washington, Division 2

October 24, 2017

STATE OF WASHINGTON, Respondent,
v.
ELIJAH ISAIAH COFIELD, Appellant. STATE OF WASHINGTON, Respondent,
v.
DEREK MATTHEW JETER, Appellant.

          Worswick, J.

         Elijah Isaiah Cofield and Derek Matthew Jeter are juvenile offenders. In accordance with RCW 13.50.260, the juvenile court set an administrative record-sealing hearing. At the hearing, the State argued that neither Cofield nor Jeter was eligible for record sealing because they had not completed the terms and conditions of their dispositions. The juvenile court commissioner did not seal either Cofield's or Jeter's juvenile court records and did not set contested record-sealing hearings. Cofield and Jeter filed motions to revise the commissioner's rulings, arguing that they were entitled to contested hearings. A superior court judge denied the motions to revise.

         We hold that the plain language of RCW 13.50.260(1)[1] requires that a juvenile offender receive a contested record-sealing hearing when the juvenile court receives any objection to his record being sealed at the administrative record-sealing hearing. Accordingly, we reverse the superior court's orders denying Cofield's and Jeter's motions to revise and remand to the juvenile court for contested record-sealing hearings.

         FACTS

         I. Procedural Facts

         In March 2013, the State charged Cofield with several crimes. The juvenile court found Cofield guilty upon stipulated facts and granted him a deferred disposition. The juvenile court later entered an amended disposition order and set an administrative record-sealing hearing, as required by RCW 13.50.260. A condition of Cofield's disposition required that he pay $2, 929.14 in restitution.

         Similarly, the State charged Jeter with two crimes in July 2014. Jeter entered an Alford plea.[2] The juvenile court entered a disposition order and required that Jeter write a letter of apology to the victim involved in his charges and complete 30 hours of community service as conditions of his disposition. At the disposition hearing, the juvenile court also set a RCW 13.50.260 administrative record-sealing hearing.

         At Cofield's and Jeter's administrative record-sealing hearings, the State argued that neither Cofield nor Jeter was eligible to have their records sealed because they had not completed the terms and conditions of their dispositions. The State noted that Cofield had not paid all restitution and that Jeter had neither completed his community service requirement nor written a letter of apology. Cofield and Jeter argued that the State's comments were objections to the administrative sealing of their juvenile court records, which required the court to set contested record-sealing hearings under RCW 13.50.260(1). Cofield and Jeter also moved to set the matter for contested record-sealing hearings. The juvenile court commissioner ordered that neither Cofield's nor Jeter's records be sealed and denied Cofield's and Jeter's motions for a contested hearing.

         Cofield and Jeter each filed motions to revise the juvenile court commissioner's rulings. A superior court judge denied Cofield's and Jeter's motions to revise, determining that they were ineligible for the contested record-sealing hearing. Cofield and Jeter appeal.[3]

         II. History of Sealing Juvenile Offenders' Records

         In 1977, the Washington legislature passed the Juvenile Justice Act of 1977 (JJA). Laws OF 1977, 1st Ex. Sess., ch. 291. The JJA constituted a significant restructuring of the juvenile justice system and "changed the philosophy and methodology of addressing the personal and societal problems of juvenile offenders." State v. Lawley, 91 Wn.2d 654, 659, 591 P.2d 772 (1979). The JJA sought to protect juvenile offenders '"against [the] consequences of adult conviction such as the loss of civil rights, [and] the use of adjudication against him in subsequent proceedings.'" State v. Hamedian, 188 Wn.App. 560, 569, 354 P.3d 937 (2015) (alterations in original) (internal quotation marks omitted) (quoting Munroe v. Soliz, 132 Wn.2d 414, 420-21, 939 P.2d 205 (1997)).

         "The legislature has always treated juvenile court records as distinctive and as deserving of more confidentiality than other types of records." State v. S.J.C., 183 Wn.2d 408, 417, 352 P.3d 749 (2015). Additionally, the JJA has historically provided a mechanism for juvenile offenders to have their records sealed. State v. J.C., 192 Wn.App. 122, 128, 366 P.3d 455 (2016). The legislature designed this mechanism for sealing juvenile court records specifically so that juvenile offenders can overcome prejudice and reintegrate into society. See Laws of 1977, 1st Ex. Sess., ch. 291, § 12.

         Until 2014, the JJA provided that juvenile offenders must file a motion to seal their records. See former RCW 13.50.050(12) (2012). In 2014, the legislature amended and recodified the JJA's provisions regarding juvenile court record sealing in RCW 13.50.260. Laws of 2014, ch. 175, ยงยง 3-5. In passing RCW 13.50.260, the legislature placed responsibility on the juvenile court, instead of the juvenile offender, to initiate the ...


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