Wash. Rev. Code » Title 9 · Chapter 9.94A
Revised Code of Washington

Wash. Rev. Code § 9.94A.730 (2026)

✓ current as of May 2026
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(1) Notwithstanding any other provision of this chapter, any person convicted of one or more crimes committed prior to the person's 18th birthday may petition the indeterminate sentence review board for early release after serving no less than 20 years of total confinement, provided the person has not been convicted for any crime committed subsequent to the person's 18th birthday, the person has not committed a disqualifying serious infraction as defined by the department in the 12 months prior to filing the petition for early release, and the current sentence was not imposed under RCW 10.95.030 or 9.94A.507.
(2) No later than five years prior to the date the offender will be eligible to petition for release, the department shall conduct an assessment of the offender and identify programming and services that would be appropriate to prepare the offender for return to the community. To the extent possible, the department shall make programming available as identified by the assessment.
(3) No later than 180 days from receipt of the petition for early release, the department shall conduct, and the offender shall participate in, an examination of the person, incorporating methodologies that are recognized by experts in the prediction of dangerousness, and including a prediction of the probability that the person will engage in future criminal behavior if released on conditions to be set by the board. The board may consider a person's failure to participate in an evaluation under this subsection in determining whether to release the person. The board shall order the person released under such affirmative and other conditions as the board determines appropriate, unless the board determines by a preponderance of the evidence that, despite such conditions, it is more likely than not that the person will commit new criminal law violations if released. The board shall give public safety considerations the highest priority when making all discretionary decisions regarding the ability for release and conditions of release.
(4) In a hearing conducted under subsection (3) of this section, the board shall provide opportunities for victims and survivors of victims of any crimes for which the offender has been convicted to present statements as set forth in RCW 7.69.032. The procedures for victim and survivor of victim input shall be provided by rule. To facilitate victim and survivor of victim involvement, county prosecutor's offices shall ensure that any victim impact statements and known contact information for victims of record and survivors of victims are forwarded as part of the judgment and sentence.
(5) Any person released by the board pursuant to this section shall comply with conditions imposed or modified pursuant to RCW 9.94A.704(10), in addition to court-imposed conditions.
(6) An offender released by the board is subject to the supervision of the department for a period of time to be determined by the board, up to the length of the court-imposed term of incarceration. The department shall monitor the offender's compliance with conditions of community custody imposed by the court or board and promptly report any violations to the board. Any violation of conditions of community custody established or modified by the board are subject to the provisions of RCW 9.95.425 through 9.95.440.
(7) An offender whose petition for release is denied may file a new petition for release five years from the date of denial or at an earlier date as may be set by the board.
(8) An offender released under the provisions of this section may be returned to the institution at the discretion of the board if the offender is found to have violated a condition of community custody. The offender is entitled to a hearing pursuant to RCW 9.95.435. If the board finds that the offender has committed a new violation, the board may return the offender to the institution for up to the remainder of the court-imposed term of incarceration. The offender may file a new petition for release five years from the date of return to the institution or at an earlier date as may be set by the board.
[ 2024 c 118 s 4; 2015 c 134 s 6; 2014 c 130 s 10.]

Notes:

Application—Effective date—2024 c 118: See notes following RCW 9.94A.704.
Effective date—2015 c 134: See note following RCW 9.94A.501.
Effective date—2014 c 130: See note following RCW 9.94A.510.
Notes of Decisions
Cited in 51 cases (27 in the last 5 years), 2015–2026 · leading case: State v. Scott, 416 P.3d 1182 (Wash. 2018).
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State v. Scott, 416 P.3d 1182 (Wash. 2018). · cites it 69× “2d 599 (2016), we hold that RCW 9.94A.730's parole provision is an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile.”
In re Pers. Restraint of Ali, 474 P.3d 507 (Wash. 2020). · cites it 9× “The State argues that Washington’s Miller-fix statute, RCW 9.94A.730, is an adequate remedy because it would allow Ali to petition for early release after serving 20 years of his 26 year sentence.”
In re Pers. Restraint of Brooks, 480 P.3d 399 (Wash. 2021). · cites it 19× “BACKGROUND In 1978, 17-year-old Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon.”
State v. Houston-Sconiers, 391 P.3d 409 (Wash. 2017). · cites it 3× “130, § 10 (codified at RCW 9.94A.730). The following year, the legislature amended the firearm enhancement statute at issue in this case to allow inmates sentenced under that statute to petition for early release under the 2014 act.”
State v. Ramos, 387 P.3d 650 (Wash. 2017). · cites it 3× “The appeal is not moot ¶22 After Ramos’ second resentencing, our legislature enacted RCW 9.94A.730 in response to the ever-evolving jurisprudence regarding juvenile sentencing.”
In re Pers. Restraint of Dodge, 502 P.3d 349 (Wash. 2022). · cites it 35× “That new law gave people like Dodge—who received lengthy sentences for crimes committed as juveniles—a chance for earlier release, after serving at least 20 years of their sentence. Two portions of that statute are key to our decision today.”
State Of Washington v. Brian Ronquillo, 361 P.3d 779 (Wash. Ct. App. 2015). · cites it 4× “” RCW 9.94A.730(1). Early release after 20 years is presumptive in such cases subject to conditions the board may see fit to impose, unless the board determines that even with conditions, “it is more likely than not that the person will commit new criminal law violations if…”
State Of Washington v. Jai'mar Scott, 385 P.3d 783 (Wash. Ct. App. 2016). · cites it 7× “But because Washington’s Miller fix statute, RCW 9.94A.730, provides the opportunity for parole and cures any Miller violation, we reverse.”
Pers. Restraint Petition Of Anthony Ryan Pugh, 433 P.3d 872 (Wash. Ct. App. 2019). · cites it 24× “130, § 10 (codified at RCW 9.94A.730). 2 Pugh’s current earned release date is February 2020.”
Pers. Restraint Petition Of: Gail Ann Brashear, 430 P.3d 710 (Wash. Ct. App. 2018). · cites it 22× “After serving 20 years of confinement, she petitioned the ISRB for early release pursuant to RCW 9.94A.730, a 2014 statute governing review of juvenile sentences.”
State v. Bassett, 428 P.3d 343 (Wash. 2018). “RCW 9.94A.730(1). This extreme jump from eligibility for release after 20 years to life without parole shows the extreme severity of the sentence in the broader context of juvenile sentencing.”
In re Pers. Restraint of Domingo-Cornelio, 474 P.3d 524 (Wash. 2020). “Unlike in Ali, the State does not contend that the Miller-fix statute, RCW 9.94A.730, could provide adequate relief to Domingo- Cornelio.”
Show all 51 citing cases →
— Wash. Rev. Code § 9.94A.730(1) — 24 cases
State v. Scott, 416 P.3d 1182 (Wash. 2018). “2d 599 (2016), we hold that RCW 9.94A.730's parole provision is an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile.”
State Of Washington v. Brian Ronquillo, 361 P.3d 779 (Wash. Ct. App. 2015). “” RCW 9.94A.730(1). Early release after 20 years is presumptive in such cases subject to conditions the board may see fit to impose, unless the board determines that even with conditions, “it is more likely than not that the person will commit new criminal law violations if…”
State v. Ramos, 387 P.3d 650 (Wash. 2017). “The appeal is not moot ¶22 After Ramos’ second resentencing, our legislature enacted RCW 9.94A.730 in response to the ever-evolving jurisprudence regarding juvenile sentencing.”
State v. Bassett, 428 P.3d 343 (Wash. 2018). “RCW 9.94A.730(1). This extreme jump from eligibility for release after 20 years to life without parole shows the extreme severity of the sentence in the broader context of juvenile sentencing.”
In re Pers. Restraint of Brooks, 480 P.3d 399 (Wash. 2021). “BACKGROUND In 1978, 17-year-old Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon.”
— Wash. Rev. Code § 9.94A.730(2) — 1 case
Pers. Restraint Petition Of Anthony Ryan Pugh, 433 P.3d 872 (Wash. Ct. App. 2019). “130, § 10 (codified at RCW 9.94A.730). 2 Pugh’s current earned release date is February 2020.”
— Wash. Rev. Code § 9.94A.730(3) — 15 cases
State v. Scott, 416 P.3d 1182 (Wash. 2018). “2d 599 (2016), we hold that RCW 9.94A.730's parole provision is an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile.”
Pers. Restraint Petition Of Anthony Ryan Pugh, 433 P.3d 872 (Wash. Ct. App. 2019). “130, § 10 (codified at RCW 9.94A.730). 2 Pugh’s current earned release date is February 2020.”
In re Pers. Restraint of Dodge, 502 P.3d 349 (Wash. 2022). “That new law gave people like Dodge—who received lengthy sentences for crimes committed as juveniles—a chance for earlier release, after serving at least 20 years of their sentence. Two portions of that statute are key to our decision today.”
In re Pers. Restraint of Ali, 474 P.3d 507 (Wash. 2020). “The State argues that Washington’s Miller-fix statute, RCW 9.94A.730, is an adequate remedy because it would allow Ali to petition for early release after serving 20 years of his 26 year sentence.”
In re Pers. Restraint of Brooks, 480 P.3d 399 (Wash. 2021). “BACKGROUND In 1978, 17-year-old Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon.”
— Wash. Rev. Code § 9.94A.730(4) — 1 case
Pers. Restraint Petition Of: Gail Ann Brashear, 430 P.3d 710 (Wash. Ct. App. 2018). “After serving 20 years of confinement, she petitioned the ISRB for early release pursuant to RCW 9.94A.730, a 2014 statute governing review of juvenile sentences.”
— Wash. Rev. Code § 9.94A.730(5) — 3 cases
In re Pers. Restraint of Brooks, 480 P.3d 399 (Wash. 2021). “BACKGROUND In 1978, 17-year-old Brooks pleaded guilty to eight counts of first degree robbery, first degree rape, first degree kidnapping, first degree assault, second degree murder, and first degree burglary, all while armed with a deadly weapon.”
Pers. Restraint Petition Of Nicholas Edward Anderson (Wash. Ct. App. 2022).
State of Washington v. Curtis Brian Fisher (Wash. Ct. App. 2024).
— Wash. Rev. Code § 9.94A.730(6) — 2 cases
State v. Scott, 416 P.3d 1182 (Wash. 2018). “2d 599 (2016), we hold that RCW 9.94A.730's parole provision is an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile.”
In the Matter of the Pers. Restraint of: Lyle Roetcisoender, Jr. (Wash. Ct. App. 2025).
— Wash. Rev. Code § 9.94A.730(7) — 1 case
In the Matter of the Pers. Restraint of: Lyle Roetcisoender, Jr. (Wash. Ct. App. 2025).
— Wash. Rev. Code § 9.94A.730(8) — 1 case
In the Matter of the Pers. Restraint of: Lyle Roetcisoender, Jr. (Wash. Ct. App. 2025).
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