Case Citator › State v. Brown

State v. Brown

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Supreme Court of Washington
Citation
983 P.2d 608
Decided
Confirmed treatments
1
Flagged citations read
41 of 41
Citing cases (total)
41
Treatment dates
2017
Overruled in part
A reviewed court has overruled part of this case’s holding. State v. Brown was overruled in part for juvenile sentencing. All 41 flagged citations have been read.
More on how this was screened

State v. Houston-Sconiers held that sentencing courts must have discretion to reduce otherwise mandatory enhancements for juveniles. Brown's enhancement rule remains binding for adults, and its separate ruling on jurors' use of trial exhibits remains intact. Later opinions repeatedly report the Houston-Sconiers ruling; the entry below quotes that Washington Supreme Court opinion itself. In State v. Kelly (2024), the same court declined to overrule Brown's surviving enhancement rule for adults.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

41 later cases cite State v. Brown; 41 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on State v. Brown?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in part

  • The Washington Supreme Court overruled Brown's rule barring departures from mandatory sentence enhancements as applied to juveniles.

    State v. Houston-Sconiers · Supreme Court of Washington · filed

    To the extent our state statutes have been interpreted to bar such discretion with regard to juveniles, 5 they are overruled. Trial courts must consider mitigating qualities of youth at sentencing and must have discretion to impose any sentence below the otherwise applicable SRA range and/or sentence enhancements. 6 5 Cf State v. Brown, 139 Wn.2d 20, 29, 983 P.2d 608 (1999) (holding that trial courts lack discretion to run sentence enhancements concurrently, even as an exceptional sentence; no separate discussion of juveniles).
    Read the full opinion on CourtListener →

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