State v. A.M.W.

The defendant pleaded guilty to fourth-degree assault in March 2022 and was placed under community supervision with conditions, including refraining from alcohol use. The defendant violates these conditions multiple times, resulting in the state moving for a bench warrant on the grounds that the defendnat posed a serioust threat to public safety under JuCR 7.16, which requires a finding that the individual circumstances of the violation or failure to appear pose a serious threat to public safety before a warrant can be issued. The defendant argued that JuCR 7.16 conflicted with RCW 13.40.040(1)(a), which allows a juvenile defendant to be taken into custody if there is probable cause to believe the juvenile has committed an offense or violated a court order. The Washington Supreme Court held that JuCR 7.16 is a procedural rule because it governs the issuance of warrants, which are part of the court’s process for bringing individuals into court. In doing so, the court rejected the defendant’s argument that JuCR 7.16's significant impact on the enforcement of the Juvenile Justice Act transforms it into a substantive rule. Lastly, the court determined that JuCR 7.16 and RCW 13.40.040 can be harmonized by treating the rule’s requirements as an additional prerequisite to the statute’s probable cause standard.