State v. S.J.C.; Sealing of Juvenile Records
The Washington State Supreme Court recently ruled on a case, State v. SJC, which presented the question of whether the Washington State Constitution, Art. I Sec. 10 – Administration of Justice requires the court to apply the Ishikawa factors when a former juvenile offender has satisfied the statutory requirements of RCW 13.50.050 to seal his or her juvenile court record. The juvenile court held that it does not require the court to do so and the Supreme Court affirmed its decision.
S.J.C. pleaded guilty to two counts of fourth degree assault with sexual motivation for offenses he committed at age 13. He was ordered to complete two years of community supervision., regularly attend school, complete sexual deviancy treatment, and pay a victim penalty assessment. After completing all of his conditions roughly three years after receiving his sentence, S.J.C. moved to vacate his adjudication and seal his juvenile record under RCW 13.50.050. Even though it conceded that S.J.C. had met the statutory requirements for vacation and sealing of his juvenile offense, the State still opposed his motion on the ground that article I, section 10 required a juvenile to show that sealing was justified under an Ishikawa analysis. The juvenile court disagreed and held that the analysis did not apply.
The State Supreme Court decided that article I, section 10 does not apply to the statutory sealing of juvenile court records. Upon application of the “logic and experience” test of review, it concluded that juvenile courts have been treated differently than adult courts. Furthermore, it took note of how “the legislature has always set policies specifically regarding restricting the openness of juvenile court records” and agrees with the intent of the legislature’s distinction between juvenile and adult courts to rehabilitate and reintegrate youth into society (pg. 11 of the opinion). While it is important to hold juveniles accountable for their crimes, they must also be allowed the opportunity to be reintegrated into society. For that purpose, the court states, “juvenile records should be treated as separate from, and deserving of more confidentiality than, other types of court records” (15).
Essentially, the Ishikawa factors do not apply here because they should not apply to juvenile cases in general. To apply them in this case, and thus prevent the sealing and vacation of S.J.C.’s juvenile offenses when he has met every statutory requirement of doing so, would undermine the purpose of having a separate system for juvenile justice.
The S.J.C decision, along with recent changes in the statute for the sealing of juvenile records, are good news for all who support a liberal policy toward the sealing of juvenile records.
