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.
that the plain language of RCW 13.50.260(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
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.
the State charged Jeter with two crimes in July 2014. Jeter
entered an Alford plea. 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.
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
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.
History of Sealing Juvenile Offenders' Records
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)).
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.
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,
§§ 3-5. In passing RCW 13.50.260, the legislature
placed responsibility on the juvenile court, instead of the
juvenile offender, to initiate the ...