downward departure standard (Washington) · Go Syfert
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downward departure standard in Washington

10 Washington opinions name it 2 courts 1994–2025 3 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.

Followed or applied (1)

CaseFollowedCited
In re Pers. Restraint of Monschkegreen
wash · 2021 · cited in 1 Washington opinions naming this issue, 2025–2025
1 sentence

2025This argument ignores that Monschke held, with five votes, that mandatory LWOP sentences under RCW 10.95.030 are unconstitutional when applied to 18- to 20-year-old offenders because they fail to allow for consideration of youth, in violation of our constitution’s prohibition on cruel punishment. 197 Wn.2d at 306-07, 326 (Gordon McCloud, J., lead opinion), 329 (González, C.J., concurring) (stating that “I concur with the lead opinion that the petitioners are entitled to a new sentencing hearing to determine whether their ages at the time of their crimes are a mitigating factor justifying a dow

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (11)

CaseCitedYears
State v. Garcia-Martinez green
washctapp · 1997
2 sentences

2016State v. Garcia-Martinez, 88 Wn.

2016State v. Garcia-Martinez, 88 Wn.

32016–2016
State v. Grewe green
wash · 1991
2 sentences

1995State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)). [14] We examine in turn whether each of the three challenged reasons may be provided by a trial court as a legitimate justification for a downward departure from the standard sentence range under the framework just elaborated. *726 A "Extraordinarily Small Amount" of a Controlled Substance We first examine the trial court's reliance on the fact Alexander's crime involved only an "extraordinarily small amount" of cocaine as a reason for departure from the standard rang

1995State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)). [14] We examine in turn whether each of the three challenged reasons may be provided by a trial court as a legitimate justification for a downward departure from the standard sentence range under the framework just elaborated. *726 A "Extraordinarily Small Amount" of a Controlled Substance We first examine the trial court's reliance on the fact Alexander's crime involved only an "extraordinarily small amount" of cocaine as a reason for departure from the standard rang

21995–2021
State v. Smith green
wash · 1993
2 sentences

1995State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)). [14] We examine in turn whether each of the three challenged reasons may be provided by a trial court as a legitimate justification for a downward departure from the standard sentence range under the framework just elaborated. *726 A "Extraordinarily Small Amount" of a Controlled Substance We first examine the trial court's reliance on the fact Alexander's crime involved only an "extraordinarily small amount" of cocaine as a reason for departure from the standard rang

1995State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)). [14] We examine in turn whether each of the three challenged reasons may be provided by a trial court as a legitimate justification for a downward departure from the standard sentence range under the framework just elaborated. *726 A "Extraordinarily Small Amount" of a Controlled Substance We first examine the trial court's reliance on the fact Alexander's crime involved only an "extraordinarily small amount" of cocaine as a reason for departure from the standard rang

21995–2021
State v. Hughes red
wash · 2005
1 sentence

2021Second, the asserted aggravating factor must be sufficiently substantial and compelling to distinguish the crime in question from others in the same category.” State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (emphasis added) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)), overruled in part on other grounds, State v. Hughes, 154 Wn.2d 118, 140 , 110 P.3d 192 (2005).

12021–2021
State v. Hughes red
wash · 2005
1 sentence

2021Second, the asserted aggravating factor must be sufficiently substantial and compelling to distinguish the crime in question from others in the same category.” State v. Smith, 123 Wn.2d 51, 57 , 864 P.2d 1371 (1993) (emphasis added) (quoting State v. Grewe, 117 Wn.2d 211, 215-16 , 813 P.2d 1238 (1991)), overruled in part on other grounds, State v. Hughes, 154 Wn.2d 118, 140 , 110 P.3d 192 (2005).

12021–2021
State v. O'Dell green
wash · 2015
2 sentences

2021I part company, however, with its analysis of the retroactivity of State v. O’Dell, 183 Wn.2d 680 , 358 P.3d 359 (2015).

2021I part company, however, with its analysis of the retroactivity of State v. O’Dell, 183 Wn.2d 680 , 358 P.3d 359 (2015).

12021–2021
Miller v. Alabama green
scotus · 2012
1 sentence

2020Cf. Ramos, 187 Wn.2d at 436 ; Montgomery, 136 S. Ct. at 726 (citing Miller, 567 U.S. at 479-80 ).

12020–2020
State v. Ramos green
wash · 2017
1 sentence

2020Cf. Ramos, 187 Wn.2d at 436 ; Montgomery, 136 S. Ct. at 726 (citing Miller, 567 U.S. at 479-80 ).

12020–2020
Montgomery v. Louisiana green
· 2016
1 sentence

2020Cf. Ramos, 187 Wn.2d at 436 ; Montgomery, 136 S. Ct. at 726 (citing Miller, 567 U.S. at 479-80 ).

12020–2020
State v. Davis green
washctapp · 2008
1 sentence

2020The State discussed the jury’s special verdict finding that Carson sold methamphetamine within 1,000 feet of a school bus stop at the sentencing hearing, but this special verdict alone did not support the imposition of the enhancements consecutively to each other. 7 No. 52812-6-II To the extent the State argues that the trial court’s sentence was proper because it satisfied the three-pronged test for an exceptional sentence articulated in State v. Davis, we reject that argument. 146 Wn.

12020–2020
State v. Nelson green
wash · 1987
2 sentences

1994The State cites State v. Nelson, 108 Wn.2d 491 , 740 P.2d 835 (1987) as support for its argument that a secondary role in a crime is not a "substantial and compelling reason to leave the standard range”.

1994The State cites State v. Nelson, 108 Wn.2d 491 , 740 P.2d 835 (1987) as support for its argument that a secondary role in a crime is not a "substantial and compelling reason to leave the standard range”.

11994–1994

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9.94A.535 (5) WA § Wash. Rev. Code § 2.06.040 (4) WA § Wash. Rev. Code § 9.94A.589 (4) WA § Wash. Rev. Code § 9.94A.010 (3) WA § Wash. Rev. Code § 9A.44.079 (3)

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.

Where else courts name it

WA 10 (1994–2025) NY 9 (2013–2026) FL 5 (2002–2019)

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.

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