Washington Court Reverses 260-Month Sentence for Defendant Who Committed Offenses at Age 16
Recent Cases in Law and Neuroscience, Curated by the Center for Law, Brain & Behavior and the Shen Neurolaw Lab with support from the Dana Foundation
On December 15, 2020, the Court of Appeals of Washington reversed Dakota Mikalle Collins’ sentence and remanded the case to the trial court for resentencing in order to consider his youth as a mitigating factor. Collins had been sentenced to 260 months for offenses committed at age 16.
When Collins was 16 years old, he shot and killed Lorenzo Parks during an attempted robbery. Collins was charged with second-degree murder, among other charges, as an adult. The trial court denied Collins’ motion for a sentence mitigation “based on his youth and the circumstances of his childhood[,]” and sentenced Collins to 260 months in prison. Collins appealed.
The appeals court initially rejected Collins’ arguments, but Collins appealed that decision to the Washington Supreme Court, which remanded the case for reconsideration in light of State v. Delbosque, 195 Wn.2d 106, 456 P.3d 806 (2020). That case had “clarified that sentencing courts must fully and meaningfully consider on the record how the characteristics of youth may mitigate the culpability of a juvenile offender.”
The appeals court therefore reconsidered Collins’ two arguments: that “the automatic decline of juvenile court jurisdiction violated his right to due process and that the trial court failed to adequately consider his youth as a mitigating factor when sentencing him.”
During trial, the court had minimized the importance of adolescence and focused on “the insignificance of an 18th birthday,” stating that “nothing miraculous happens on your 18th birthday. You don’t suddenly have your brain fully developed so that you’re now going to make good choices and now going to be able to assess risks and consequences of your behavior differently than you did the day before you turned 18.”
The appeals court noted that this reasoning was inconsistent with Miller v. Alabama and its progeny, as it used Collins’ youth against him rather than understanding his age to be a mitigating factor. The appeals court also noted that Collins was not at all close to his 18th birthday when he committed the offenses, as he was only 16 years old.
Also at trial, an expert testified that “adolescent brains are less developed in the prefrontal cortex, the area responsible for exercising judgment and understanding consequences.” Collins also had PTSD, and the expert explained that Collins’ adolescence and PTSD combined “really compounded his situation in terms of how he perceived the events as they unfolded that night, perceived the situation as threatening, and responded in that reactive impulsive way with lethal violence.”
The appeals court agreed with Collins and found that the trial court had “failed to fully and meaningfully consider the influence of age and its hallmark features, as well as the effects of Collins’s PTSD diagnosis, when it focused on the irrelevance of Collins’s 18th birthday as a turning point and failed to adequately address expert testimony.”
The appeals court reversed the trial court’s initial sentence and remanded for resentencing, noting that the trial court was free to exercise its “broad discretion” when fashioning the sentence “so long as it complies with the requirements imposed by the Supreme Court” and considers Collins’ youth.
Key words: Miller v. Alabama, adolescent brain, PTSD, Washington
Citation: State v. Collins, 2020 WL 7365814
This post is the 46th post as part of an ongoing Center for Law, Brain & Behavior (CLBB) series tracking the latest developments in law and neuroscience cases. To see previous posts about recent cases, see the full case archive on the CLBB website. To see updates on legal scholarship, see the Neurolaw News, hosted by the MacArthur Foundation Research Network on Law and Neuroscience. This project is made possible through support of the Dana Foundation.
