October 2022 Bar Bulletin
By Christopher L. Young
State v. Anderson, No. 97890-5 (Sept. 8, 2022). Washington’s Supreme Court raised a few eyebrows this past month in what some describe as a departure from previous Miller-fix rulings. At issue: whether a 61-year sentence imposed on a person convicted of first-degree murders committed at the age of 17 violates Washington’s constitution. As recently as last year, the Court concluded that a juvenile who had been resentenced under the Miller-fix statutes to 46 years behind bars had been given a de facto life sentence. Here, however, a majority of the Court concluded differently.
The Court will reverse a sentence only for clear...