In re Pers. Restraint of Schoenhals

CourtWashington Supreme Court
DecidedSeptember 25, 2025
Docket103,672-8
StatusPublished

This text of In re Pers. Restraint of Schoenhals (In re Pers. Restraint of Schoenhals) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Pers. Restraint of Schoenhals, (Wash. 2025).

Opinion

FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON IN CLERK’S OFFICE SEPTEMBER 25, 2025 SUPREME COURT, STATE OF WASHINGTON SEPTEMBER 25, 2025 SARAH R. PENDLETON SUPREME COURT CLERK

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

No. 103672-8 In the Matter of the Personal Restraint En Banc of JOHN H. SCHOENHALS, Filed: September 25, 2025 Petitioner.

PER CURIAM 1 — In 1986, John H. Schoenhals received a mandatory

sentence of life in prison without the possibility of parole (LWOP). In the opinions

that follow, the court unanimously holds that Schoenhals’ personal restraint petition

(PRP) is timely and should be granted because his 1986 mandatory LWOP sentence

for aggravated first degree murder committed at age 20 is unconstitutional.

However, the opinions differ in their reasoning.

In the lead opinion, four justices—Whitener, J., González, J., Montoya-Lewis,

J., and Mungia, J.— reason as follows: (1) This court’s decision in In re Personal

Restraint of Monschke, 197 Wn.2d 305, 482 P.3d 276 (2021) (plurality decision),

announced a new substantive constitutional rule that meets the “significant change

in the law” retroactive exemption to the one-year time bar on collateral relief

1 This court may issue a per curiam opinion summarizing the votes of the justices in a plurality decision, preceding the lead opinion. Wash. Sup. Ct. Internal R. II-8(B).

1 contained in RCW 10.73.100(7). (2) A Monschke violation per se satisfies an actual

and substantial prejudice requirement. (3) A personal restraint petitioner can

establish actual and substantial prejudice by a preponderance of the evidence if they

can show that Monschke is material to their sentence.

In a concurring opinion, four justices—Madsen, J., Stephens, C.J., Johnson,

J., and Yu, J.— reason as follows: (1) Based on State v. Carter, 3 Wn.3d 198, 548

P.3d 935 (2024), Schoenhals’ judgment and sentence is facially invalid and thus

exempt from the time bar under RCW 10.73.090(1). (2) It is therefore unnecessary

to analyze whether Monschke constitutes a significant change in the law under RCW

10.73.100(7) and what a petitioner must show to demonstrate actual and substantial

prejudice.

In a separate concurring opinion, Gordon McCloud, J., agrees with aspects of

the analysis in both the lead opinion by Whitener, J., and the concurring opinion by

Madsen, J., that Schoenhals’ sentence is exempt from the time bar for collateral

attacks and that his sentence is unconstitutional.

The PRP is granted, and the case is remanded to the trial court for a new

sentencing hearing.

2 FILE THIS OPINION WAS FILED FOR RECORD AT 8 A.M. ON IN CLERK’S OFFICE SEPTEMBER 25, 2025 SUPREME COURT, STATE OF WASHINGTON SEPTEMBER 25, 2025 SARAH R. PENDLETON SUPREME COURT CLERK

In the Matter of the Personal Restraint of No. 103672-8

JOHN H. SCHOENHALS, En Banc

Petitioner.

Filed: September 25, 2025

WHITENER, J. – In 1986, John H. Schoenhals received a mandatory life

without parole (LWOP) sentence for aggravated first degree murder he committed

when he was 20 years old. In 2021, we held that defendants convicted of aggravated

first degree murder who were 18 to 20 years old at the time of the offense and

sentenced to mandatory LWOP are entitled to resentencing, where the sentencing

court must consider mitigating evidence of the defendant’s youth. In re Pers.

Restraint of Monschke, 197 Wn.2d 305, 306-07, 326, 482 P.3d 276 (2021) (plurality

opinion). Schoenhals argues that Monschke constitutes a “significant change in the

law” exception to the one-year time bar for collateral relief under RCW

10.73.100(7). We agree. In re Pers. Restraint of Schoenhals, No. 103672-8

We grant Schoenhals’ personal restraint petition (PRP) and remand to the trial

court for a new sentencing hearing. Under Monschke, Schoenhals’ LWOP sentence

is unconstitutional because the original sentencing court did not have discretion to

consider the mitigating qualities of Schoenhals’ youth when it imposed a mandatory

LWOP sentence for aggravated murder committed when he was 20 years old.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

I. Factual Background

John Schoenhals was 20 years old in 1985 when he burglarized the home of

the Wallace family. During the burglary, he stole firearms and other items in the

home, and fatally stabbed Mark Wallace, a 14-year-old boy. In 1986, a jury

convicted Schoenhals of aggravated first degree murder. RCW 10.95.020. At the

time of Schoenhals’ sentencing, LWOP was the mandatory sentence required under

the law. RCW 10.95.030(1).1 When he imposed the mandatory sentence, the original

sentencing judge stated that “[t]he law as written gives the Court no alternative, and

I hereby sentence the defendant Mr. John Schoenhals to life imprisonment without

possibility of parole.” Pet’r Schoenhals’ Suppl. Br. at 21-22 (alteration in original).

Schoenhals has been incarcerated for 40 years.

1 RCW 10.95.030(1) has been amended since Schoenhals’ conviction in 1986. Because these amendments do not impact the statutory language relied on by this court, we refer to the current version of the statute. 2 In re Pers. Restraint of Schoenhals, No. 103672-8

II. Procedural History

In 1986, a sentencing court imposed on Schoenhals the statutorily mandated

LWOP sentence. The Court of Appeals affirmed Schoenhals’ conviction and LWOP

sentence. The mandate was issued on December 7, 1988.

In March 2023, Schoenhals filed a motion for resentencing in King County

Superior Court based on this court’s decision in Monschke. 197 Wn.2d at 306, 326.

He argued that his motion was exempt from the one-year time limit on collateral

relief because his sentence is unconstitutional and because there had been a

significant change in the law. RCW 10.73.100(2), (7). The superior court transferred

the motion to Division One of the Court of Appeals for treatment as a PRP pursuant

to CrR 7.8(c)(2). The Court of Appeals issued an order certifying the PRP to this

court for direct consideration pursuant to RCW 2.06.030(d), and we accepted review

on the merits.

ISSUES

1. Is Monschke a “significant change in the law” under the exemption to the one-

year time bar for collateral relief under RCW 10.73.100(7)?

2. What must Monschke petitioners show to demonstrate they were actually and

substantially prejudiced in order to obtain collateral relief?

3 In re Pers.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Woodson v. North Carolina
428 U.S. 280 (Supreme Court, 1976)
Teague v. Lane
489 U.S. 288 (Supreme Court, 1989)
Schriro v. Summerlin
542 U.S. 348 (Supreme Court, 2004)
Danforth v. Minnesota
552 U.S. 264 (Supreme Court, 2008)
Rhoades v. State
233 P.3d 61 (Idaho Supreme Court, 2010)
State v. Grisby
647 P.2d 6 (Washington Supreme Court, 1982)
In Re the Personal Restraint of Cook
792 P.2d 506 (Washington Supreme Court, 1990)
In Re Davis
101 P.3d 1 (Washington Supreme Court, 2004)
In Re Bonds
196 P.3d 672 (Washington Supreme Court, 2008)
State v. Evans
114 P.3d 627 (Washington Supreme Court, 2005)
In Re Turay
74 P.3d 1194 (Washington Supreme Court, 2003)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
Montgomery v. Louisiana
577 U.S. 190 (Supreme Court, 2016)
State v. Houston-Sconiers
391 P.3d 409 (Washington Supreme Court, 2017)
In re Pers. Restraint of Light-Roth
422 P.3d 444 (Washington Supreme Court, 2018)
In re Pers. Restraint of Monschke
482 P.3d 276 (Washington Supreme Court, 2021)
Edwards v. Vannoy
593 U.S. 255 (Supreme Court, 2021)
In re Pers. Restraint of Ali
474 P.3d 507 (Washington Supreme Court, 2020)
In re the Personal Restraint of Snively
320 P.3d 1107 (Washington Supreme Court, 2014)
State v. Finch
975 P.2d 967 (Washington Supreme Court, 1999)

Cite This Page — Counsel Stack

Bluebook (online)
In re Pers. Restraint of Schoenhals, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-pers-restraint-of-schoenhals-wash-2025.