Wash. Rev. Code » Title 13 · Chapter 13.40
Revised Code of Washington

Wash. Rev. Code § 13.40.230 (2026)

✓ current as of May 2026
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(1) Dispositions reviewed pursuant to RCW 13.40.160 shall be reviewed in the appropriate division of the court of appeals.
An appeal under this section shall be heard solely upon the record that was before the disposition court. No written briefs may be required, and the appeal shall be heard within thirty days following the date of sentencing and a decision rendered within fifteen days following the argument. The supreme court shall promulgate any necessary rules to effectuate the purposes of this section.
(2) To uphold a disposition outside the standard range, the court of appeals must find (a) that the reasons supplied by the disposition judge are supported by the record which was before the judge and that those reasons clearly and convincingly support the conclusion that a disposition within the range would constitute a manifest injustice, and (b) that the sentence imposed was neither clearly excessive nor clearly too lenient.
(3) If the court does not find subsection (2)(a) of this section it shall remand the case for disposition within the standard range.
(4) If the court finds subsection (2)(a) but not subsection (2)(b) of this section it shall remand the case with instructions for further proceedings consistent with the provisions of this chapter.
(5) The disposition court may impose conditions on release pending appeal as provided in RCW * 13.40.040(4) and 13.40.050(6).
(6) Appeal of a disposition under this section does not affect the finality or appeal of the underlying adjudication of guilt.
[ 1997 c 338 s 35; 1981 c 299 s 16; 1979 c 155 s 72; 1977 ex.s. c 291 s 77.]

Notes:

*Reviser's note: RCW 13.40.040 was amended by 2002 c 171 s 2, changing subsection (4) to subsection (5).
Finding—Evaluation—Report—1997 c 338: See note following RCW 13.40.0357.
Severability—Effective dates—1997 c 338: See notes following RCW 5.60.060.
Effective date—Severability—1979 c 155: See notes following RCW 13.04.011.
Effective dates—Severability—1977 ex.s. c 291: See notes following RCW 13.04.005.
Notes of Decisions
Cited in 94 cases (4 in the last 5 years), 1979–2025 · leading case: State v. Murphy, 669 P.2d 891 (Wash. Ct. App. 1983).
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State v. Murphy, 669 P.2d 891 (Wash. Ct. App. 1983). · cites it 11× “Murphy claims the failure of this court to decide his appeal within 45 days, pursuant to RCW 13.40.230, violated his constitutional and statutory right to appeal.”
State v. Rhodes, 600 P.2d 1264 (Wash. 1979). · cites it 5× “A disposition so imposed outside the standard range may be appealed as provided in RCW 13.40.230 by the state or the respondent.”
State v. Landrum, 832 P.2d 1359 (Wash. Ct. App. 1992). · cites it 6× “Any disposition other than community supervision may be appealed as provided in RCW 13.40.230, as now or hereafter amended, by the state or the respondent.”
State v. Bryan, 606 P.2d 1228 (Wash. 1980). · cites it 5× “[1] Pursuant to RCW 13.40.230, when Bryan appealed the manifest injustice disposition, he was released from custody after serving the few days' detention time prescribed by the sentencing standard for the offenses.”
State v. P., 686 P.2d 488 (Wash. Ct. App. 1984). · cites it 4× “The scope of appellate review is defined in RCW 13.40.230: (1) Dispositions reviewed pursuant to RCW 13.”
State v. Sledge, 947 P.2d 1199 (Wash. 1997). · cites it 2× “” RCW 13.40.230(2). Sledge argues the trial court improperly took into consideration the possibility of early release by imposing the 103-week disposition.”
State v. Oxborrow, 723 P.2d 1123 (Wash. 1986). · cites it 2× “RCW 13.40.230(2) (b). In State v. Strong, 23 Wn.”
State v. B.O.J., 449 P.3d 1006 (Wash. 2019). · cites it 2× “2d 187 (1998); RCW 13.40.230(2). "Once a juvenile court has concluded that a disposition within the standard range would effectuate a manifest injustice, the court is vested with broad discretion in determining the appropriate sentence to impose.”
State v. Rice, 655 P.2d 1145 (Wash. 1983). · cites it 2× “RCW 13.40.230(2). The manifest injustice standard, therefore, meets the requirements set forth in Rhodes , even after our holding in this case.”
State v. T.J.S.-M., 441 P.3d 1181 (Wash. 2019). · cites it 10× “¶ 13 "A disposition outside the standard range is appealable under RCW 13.40.230 by the state or the respondent.”
State v. W.W., 887 P.2d 914 (Wash. Ct. App. 1995). · cites it 11× “13 takes precedence over the conflicting provisions of RCW 13.40.230. Therefore, as a matter of statutory construction, the trial court did not err in applying JuCR 7.”
State v. Melton, 817 P.2d 413 (Wash. Ct. App. 1991). · cites it 3× “RCW 13.40.230(2). 8 Once a court determines that a disposition within the standard range would effectuate a manifest injustice, a trial court is vested with broad discretion in determining what sentence to impose.”
Show all 94 citing cases →
— Wash. Rev. Code § 13.40.230(1) — 11 cases
State v. Murphy, 669 P.2d 891 (Wash. Ct. App. 1983). “Murphy claims the failure of this court to decide his appeal within 45 days, pursuant to RCW 13.40.230, violated his constitutional and statutory right to appeal.”
State v. T.E.C., 92 P.3d 263 (Wash. Ct. App. 2004).
State v. Landrum, 832 P.2d 1359 (Wash. Ct. App. 1992). “Any disposition other than community supervision may be appealed as provided in RCW 13.40.230, as now or hereafter amended, by the state or the respondent.”
State v. P., 686 P.2d 488 (Wash. Ct. App. 1984). “The scope of appellate review is defined in RCW 13.40.230: (1) Dispositions reviewed pursuant to RCW 13.”
State v. T.J.S.-M., 441 P.3d 1181 (Wash. 2019). “¶ 13 "A disposition outside the standard range is appealable under RCW 13.40.230 by the state or the respondent.”
— Wash. Rev. Code § 13.40.230(2) — 65 cases
State v. B.O.J., 449 P.3d 1006 (Wash. 2019). “2d 187 (1998); RCW 13.40.230(2). "Once a juvenile court has concluded that a disposition within the standard range would effectuate a manifest injustice, the court is vested with broad discretion in determining the appropriate sentence to impose.”
State v. Rice, 655 P.2d 1145 (Wash. 1983). “RCW 13.40.230(2). The manifest injustice standard, therefore, meets the requirements set forth in Rhodes , even after our holding in this case.”
State v. Landrum, 832 P.2d 1359 (Wash. Ct. App. 1992). “Any disposition other than community supervision may be appealed as provided in RCW 13.40.230, as now or hereafter amended, by the state or the respondent.”
State v. Melton, 817 P.2d 413 (Wash. Ct. App. 1991). “RCW 13.40.230(2). 8 Once a court determines that a disposition within the standard range would effectuate a manifest injustice, a trial court is vested with broad discretion in determining what sentence to impose.”
State v. Sledge, 947 P.2d 1199 (Wash. 1997). “” RCW 13.40.230(2). Sledge argues the trial court improperly took into consideration the possibility of early release by imposing the 103-week disposition.”
— Wash. Rev. Code § 13.40.230(2)(a) — 6 cases
State v. T.E.H., 960 P.2d 441 (Wash. Ct. App. 1998).
State v. T.J.S.-M., 441 P.3d 1181 (Wash. 2019). “¶ 13 "A disposition outside the standard range is appealable under RCW 13.40.230 by the state or the respondent.”
State v. Crabtree, 116 Wash. App. 536 (Wash. Ct. App. 2003).
State v. Crabtree, 66 P.3d 695 (Wash. Ct. App. 2003).
State of Washington v. Guillermo Adam Ledezma (Wash. Ct. App. 2017).
— Wash. Rev. Code § 13.40.230(2)(b) — 11 cases
State v. Oxborrow, 723 P.2d 1123 (Wash. 1986). “RCW 13.40.230(2) (b). In State v. Strong, 23 Wn.”
State v. Strong, 599 P.2d 20 (Wash. Ct. App. 1979).
State v. Melton, 817 P.2d 413 (Wash. Ct. App. 1991). “RCW 13.40.230(2). 8 Once a court determines that a disposition within the standard range would effectuate a manifest injustice, a trial court is vested with broad discretion in determining what sentence to impose.”
State v. SH, 877 P.2d 205 (Wash. Ct. App. 1994).
State v. S.H., 75 Wash. App. 1 (Wash. Ct. App. 1994).
— Wash. Rev. Code § 13.40.230(3) — 5 cases
State v. Murphy, 669 P.2d 891 (Wash. Ct. App. 1983). “Murphy claims the failure of this court to decide his appeal within 45 days, pursuant to RCW 13.40.230, violated his constitutional and statutory right to appeal.”
State v. P., 686 P.2d 488 (Wash. Ct. App. 1984). “The scope of appellate review is defined in RCW 13.40.230: (1) Dispositions reviewed pursuant to RCW 13.”
State v. Gutierrez, 684 P.2d 87 (Wash. Ct. App. 1984).
State v. P, 686 P.2d 488 (Wash. Ct. App. 1984).
State of Washington v. Guillermo Adam Ledezma (Wash. Ct. App. 2017).
— Wash. Rev. Code § 13.40.230(4) — 2 cases
State v. P., 686 P.2d 488 (Wash. Ct. App. 1984). “The scope of appellate review is defined in RCW 13.40.230: (1) Dispositions reviewed pursuant to RCW 13.”
State v. P, 686 P.2d 488 (Wash. Ct. App. 1984).
— Wash. Rev. Code § 13.40.230(5) — 4 cases
State v. W.W., 887 P.2d 914 (Wash. Ct. App. 1995). “13 takes precedence over the conflicting provisions of RCW 13.40.230. Therefore, as a matter of statutory construction, the trial court did not err in applying JuCR 7.”
State v. Sledge, 947 P.2d 1199 (Wash. 1997). “” RCW 13.40.230(2). Sledge argues the trial court improperly took into consideration the possibility of early release by imposing the 103-week disposition.”
State v. Sledge, 947 P.2d 1199 (Wash. 1998).
State v. WW, 887 P.2d 914 (Wash. Ct. App. 1995).
— Wash. Rev. Code § 13.40.230(6) — 2 cases
Pers. Restraint Petition of M.T.M.L (Wash. Ct. App. 2025).
Pers. Restraint Petition Of M.t.m.l. (Wash. Ct. App. 2025).
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