Sunday, November 17, 2013

State v. Q.D. case brief

State v. Q.D. case brief summary
685 P.2d 557 (1984)

Defendants appealed their adjudications in the Superior Court for King County (Washington), which found that they had committed offenses which if committed by an adult would be crimes. The Court of Appeals certified to the court the questions whether the statutory presumption of infant incapacity, Wash. Rev. Code § 9A.04.050, applied to juvenile adjudications, and if it did, what standard of proof was required to rebut the presumption.

Two juvenile defendants were adjudicated based on offenses that would have been crimes if committed by adults. Defendants appealed on the ground that that the trial court's determinations of capacity were erroneous under any standard. One defendant additionally argued that there was insufficient evidence to convict him of trespass in the first degree. The appellate court certified the question of the statutory presumption of infant capacity under Wash. Rev. Code § 9A.04.050 to the court.


  • The court held that:
  • (1) Wash. Rev. Code § 9A.04.050 applied to juvenile adjudications, 
  • (2) the standard of proof necessary to rebut the presumption of incapacity was clear and convincing proof, 
  • (3) the state proved that the first defendant possessed requisite capacity, but the court did not reach the issue in the second case because 
  • (4) there was sufficient evidence of entry to convict the second defendant of trespass, and 
  • (5) the imposition of a crime victims compensation act penalty applied to juvenile court dispositions. 
  • Accordingly, the second conviction was reversed, and the first conviction and disposition were affirmed.

The court affirmed the first defendant's conviction but reversed the second defendant's conviction.

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