15 Washington opinions name it 2 courts 1997–2026 5 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
State v. Williamsgreen2 sentences2026Kent, 383 U.S. at 566-67 ; see also State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969) (adopting the Kent factors). 2026Kent, 383 U.S. at 566-67 ; see also State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969) (adopting the Kent factors). | 2 | 2 |
State v. M.A.green2 sentences2024The eight Kent factors are: (1) “[T]he seriousness of the alleged offense and whether the protection of the community requires waiver;” (2) “[W]hether the alleged offense was committed in an aggressive, violent, premeditated or willful manner;” (3) “[W]hether the alleged offense was against persons or against property;” (4) “[T]he prosecutive merit of the complaint;” (5) “[T]he desirability of trial and disposition of the entire offense in one court when the juvenile’s accomplices in the alleged offense are adults;” (6) “[T]he juvenile’s sophistication and maturity as determined by considerati 2021The Kent factors include: (1) the seriousness of the alleged offense and whether the protection of the community requires waiver; (2) whether the alleged offense was committed in an aggressive, violent, premediated or willful manner; (3) whether the alleged offense was against persons or against property; (4) the prosecutive merit of the complaint; (5) the desirability of juvenile trial and disposition of the entire offense in one court when the juvenile’s accomplices in the alleged offense are adults; (6) the juvenile’s sophistication and maturity as determined by consideration of his or her | 1 | 4 |
Kent v. United Statesgreen2 sentences2026Kent, 383 U.S. at 566-67 ; see also State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969) (adopting the Kent factors). 2026Kent, 383 U.S. at 566-67 ; see also State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969) (adopting the Kent factors). | 1 | 3 |
State v. Hollandgreen2 sentences2024See State v. Holland, 98 Wn.2d 507, 515-16 , 656 P.2d 1056 (1983). 2 In State v. Quijas, Division One of this court held that the Kent factors are not exclusive and that juvenile courts must also consider questions of systemic racial bias when raised by the defendant and “supported by some evidence in the record.” 12 Wn. 2024See State v. Holland, 98 Wn.2d 507, 515-16 , 656 P.2d 1056 (1983). 2 In State v. Quijas, Division One of this court held that the Kent factors are not exclusive and that juvenile courts must also consider questions of systemic racial bias when raised by the defendant and “supported by some evidence in the record.” 12 Wn. | 1 | 3 |
State v. Salaveagreen2 sentences2025Further, “the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction.” State v. Salavea, 151 Wn.2d 133, 140 , 86 P.3d 125 (2004) (emphasis added). 2025Further, “the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction.” State v. Salavea, 151 Wn.2d 133, 140 , 86 P.3d 125 (2004) (emphasis added). | 1 | 2 |
State v. Masseygreen2 sentences2020See State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969); see also Massey, 60 Wn. 2020See State v. Williams, 75 Wn.2d 604, 606-07 , 453 P.2d 418 (1969); see also Massey, 60 Wn. | 1 | 1 |
State v. Ricegreen2 sentences2018State v. Rice, 174 Wash.2d 884 , 889, 279 P.3d 849 (2012) ("[T]he legislature checks prosecutors ... by defining the particular acts and circumstances that may warrant criminal punishment ... and the judiciary checks ... prosecutors by reviewing probable cause."). ¶ 17 A Kent hearing has no value as an additional safeguard here because, regardless of the outcome of a Kent hearing, the juvenile court cannot exercise jurisdiction over Watkins' case. 2018State v. Rice, 174 Wash.2d 884 , 889, 279 P.3d 849 (2012) ("[T]he legislature checks prosecutors ... by defining the particular acts and circumstances that may warrant criminal punishment ... and the judiciary checks ... prosecutors by reviewing probable cause."). ¶ 17 A Kent hearing has no value as an additional safeguard here because, regardless of the outcome of a Kent hearing, the juvenile court cannot exercise jurisdiction over Watkins' case. | 1 | 1 |
United States v. Jerome T. Blandgreen2 sentences2018United States v. Bland, 153 U.S. App. D.C. 254 , 472 F.2d 1329 , 1344 n.8 (1972) (Wright, J., dissenting) (using the term ''Kent hearing"). ^ Watkins attempts to bolster his argument by pointing out that several other states have banned automatic decline statutes, including Delaware, Nevada, Missouri, and Hawaii. 2018See, e.g., United States v. Bland, 153 U.S. App. D.C. 254 , 472 F.2d 1329 , 1344 n.8 (1972) (Wright, J., dissenting) (using the term "Kent hearing"). | 1 | 1 |
State v. Houston-Sconiersgreen2 sentences2018See State v. Houston-Sconiers, 188 Wash.2d 1 , 21, 391 P.3d 409 (2017). 6 A. Former RCW 13.04.030(1) (2009) does not deprive Watkins of any due process right because there is no constitutional right to be tried in juvenile court ¶ 8 Watkins contends that due process requires a Kent hearing before a juvenile court may decline jurisdiction over a juvenile charged with one of the offenses enumerated in former RCW 13.04.030(1) (2009). 2018See State v. Houston-Sconiers, 188 Wash.2d 1 , 21, 391 P.3d 409 (2017). 6 A. Former RCW 13.04.030(1) (2009) does not deprive Watkins of any due process right because there is no constitutional right to be tried in juvenile court ¶ 8 Watkins contends that due process requires a Kent hearing before a juvenile court may decline jurisdiction over a juvenile charged with one of the offenses enumerated in former RCW 13.04.030(1) (2009). | 1 | 1 |
State v. Dallugegreen2 sentences2015See State v. Dalluge, noted at 148 Wn. 2015See State v. Dalluge, noted at 148 Wn. | 1 | 1 |
State v. Neelygreen2 sentences2007See Hegney, noted at 121 Wash.App. 1012 , 2004 WL 837904 at *3-*4, 2004 Wash.App. 2007See Hegney, noted at 121 Wash.App. 1012 , 2004 WL 837904 at *3-*4, 2004 Wash.App. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Salavea
green
2 sentences2025Further, “the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction.” State v. Salavea, 151 Wn.2d 133, 140 , 86 P.3d 125 (2004) (emphasis added). 2025Further, “the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction.” State v. Salavea, 151 Wn.2d 133, 140 , 86 P.3d 125 (2004) (emphasis added). | 2 | 2018–2025 |
State v. Williams
green
2 sentences2007Williams, 96 Wash.2d at 223 , 634 P.2d 868 . ¶ 53 Even assuming, without deciding, that the CPS records and the neuropsychological evaluation could not have been discovered before the decline hearing by the exercise of due diligence, they would not change the result of the decline hearing. ¶ 54 Hegney argues that the newly discovered CPS records [13] and neuropsychological evaluation are relevant to refute the juvenile court's findings of fact regarding the following two Kent factors: (1) the sophistication *1206 and maturity of the juvenile and (2) the prospects for adequate protection of the 2007Williams, 96 Wn.2d at 223 . ¶53 Even assuming, without deciding, that the CPS records and the neuropsychological evaluation could not have been discovered before the decline hearing by the exercise of due diligence, they would not change the result of the decline hearing. ¶54 Hegney argues that the newly discovered CPS records 13 and neuropsychological evaluation are relevant to refute the juvenile court’s findings of fact regarding the following two Kent factors: (1) the sophistication and maturity of the juvenile and (2) the prospects for adequate protection of the public and the likelihood | 2 | 2007–2007 |
In re Dependency of K.W.
green
2 sentences2024ANALYSIS Smith contends that (1) the Kent factors “must be interpreted to incorporate recent caselaw grounded in brain science” and to presume a lack of maturity and sophistication as required under Houston-Sconiers, and the juvenile court failed to consider brain science or apply this presumption, PRP at 53; (2) “the decline hearing was affected by implicit racial bias and the court’s decision to decline adopted the prosecutor’s arguments which were ‘factors that serve as proxies for race,’ ” Id. at 50 (quoting In re Dependency of K.W., 199 Wn.2d 131 , 161, 504 P.3d 207 (2022)); (3) several o 2024ANALYSIS Smith contends that (1) the Kent factors “must be interpreted to incorporate recent caselaw grounded in brain science” and to presume a lack of maturity and sophistication as required under Houston-Sconiers, and the juvenile court failed to consider brain science or apply this presumption, PRP at 53; (2) “the decline hearing was affected by implicit racial bias and the court’s decision to decline adopted the prosecutor’s arguments which were ‘factors that serve as proxies for race,’ ” Id. at 50 (quoting In re Dependency of K.W., 199 Wn.2d 131 , 161, 504 P.3d 207 (2022)); (3) several o | 1 | 2024–2024 |
State v. MA
green
1 sentence2024App. 493, 498 , 23 P.3d 508 (2001). 11 No. 56917-5-II Regarding factor 6, the committee considered Smith’s history and “felt that he is living an adult lifestyle” because he “spends several nights away from home,” and “was coming and going as he pleased.” Id. at 253. | 1 | 2024–2024 |
In Re Boot
green
2 sentences2018And "the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction." State v. Salavea, 151 Wash.2d 133 , 140, 86 P.3d 125 (2004) ; Boot, 130 Wash.2d at 570 , 925 P.2d 964 . ¶ 10 The Washington State Legislature created the juvenile court system by enacting the BJCA. 2018And "the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction." State v. Salavea, 151 Wash.2d 133 , 140, 86 P.3d 125 (2004) ; Boot, 130 Wash.2d at 570 , 925 P.2d 964 . ¶ 10 The Washington State Legislature created the juvenile court system by enacting the BJCA. | 1 | 2018–2018 |
In Re GAULT
green
2 sentences2018Juveniles charged with crimes have a right to procedural due process. re Gault, 387 U.S. 1, 30-31 , 87 S. Ct. 1428 , 18 L. 2018Juveniles charged with crimes have a right to procedural due process. re Gault, 387 U.S. 1, 30-31 , 87 S. Ct. 1428 , 18 L. | 1 | 2018–2018 |
State v. Cornejo
green
2 sentences2018And "the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction." State v. Salavea, 151 Wash.2d 133 , 140, 86 P.3d 125 (2004) ; Boot, 130 Wash.2d at 570 , 925 P.2d 964 . ¶ 10 The Washington State Legislature created the juvenile court system by enacting the BJCA. 2018And "the right [to a Kent hearing] attaches only if a court is given statutory discretion to assign juvenile or adult court jurisdiction." State v. Salavea, 151 Wash.2d 133 , 140, 86 P.3d 125 (2004) ; Boot, 130 Wash.2d at 570 , 925 P.2d 964 . ¶ 10 The Washington State Legislature created the juvenile court system by enacting the BJCA. | 1 | 2018–2018 |
Hughes v. State
green
2 sentences2018Hughes, 653 A.2d 241 . 2018Hughes, 653 A.2d 241 . | 1 | 2018–2018 |
State v. Furman
green
2 sentences2015Furman, 122 Wn.2d at 447 . 2015Furman, 122 Wn.2d at 447 . | 1 | 2015–2015 |
City of Spokane v. White
green
1 sentence2014Worthington contends that this court should waive RAP 10.3(c) and that his entire reply brief should be considered in order to “meet the ends of justice and facilitate a ruling on the merits.” RAP 10.3(c) provides that “[a] reply brief should conform with subsections (1), (2), (6), (7), and (8) of section (a) and be limited to a response to the issues in the brief to which the reply brief is directed.” “A reply brief is generally not the proper forum to address new issues because the respondent does not get an opportunity to address the newly raised issues.” City of Spokane v. White, 102 Wn. | 1 | 2014–2014 |
State v. Brokman
green
2 sentences2000No test occurs until a valid test occurs." Brokman, 84 Wash.App. at 852 , 930 P.2d 354 . [2] The City of Kent's analysis is flawed for three reasons. 2000No test occurs until a valid test occurs." Brokman, 84 Wash.App. at 852 , 930 P.2d 354 . [2] The City of Kent's analysis is flawed for three reasons. | 1 | 2000–2000 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.