Washington Juvenile Courts are subject to their own rules, which may be different from the rules and procedures that apply to a criminal trial of an adult. A juvenile being tried in a juvenile court does not have a right to a jury. RCW 13.04.021. The case is instead heard by a judge. The court must find the juvenile guilty or not guilty and state its findings of fact. The court must include the evidence it relied upon in its findings. The court must also enter written findings of fact and conclusions of law in a case that is appealed. The findings must include the ultimate facts that prove each element of the crime. JuCR 7.11. Generally, the appropriate remedy on appeal for a juvenile court’s failure to enter sufficient findings is remand to the juvenile court to enter the appropriate findings.
A juvenile recently challenged her conviction based on insufficient findings by the juvenile court. The juvenile was arrested after a woman reported seeing a girl rummaging around in her car and then riding away on a bicycle. A sergeant from the sheriff’s department found the juvenile sitting on a bicycle and looking into a truck a couple of blocks from the woman’s home. According to the appeals court opinion, the girl provided the officer with a name that was not her own. The sergeant arrested the girl. When the girl was searched, police found two knives, two speakers, and some change when she searched her.
The juvenile was charged with second degree vehicle prowling and providing a false statement to a public servant. According to the juvenile court’s findings, the woman identified the juvenile as the girl she saw in her car, based on the girl’s clothing, complexion, and build. The juvenile court found the juvenile guilty of both charges.