Personal Restraint Petition of Marvin Leo

CourtCourt of Appeals of Washington
DecidedMarch 10, 2026
Docket61187-2
StatusUnpublished

This text of Personal Restraint Petition of Marvin Leo (Personal Restraint Petition of Marvin Leo) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Personal Restraint Petition of Marvin Leo, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

March 10, 2026

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II In the Matter of the Personal Restraint of: No. 61187-2-II

MARVIN LOFI LEO, UNPUBLISHED OPINION Petitioner.

CRUSER, C.J.—Marvin Lofi Leo was originally sentenced to life without the possibility of

parole plus 1,100 months for the crimes of aggravated murder in the first degree and assault in the

first degree that he committed when he was 17 years old. At a resentencing hearing, the trial court

resentenced Leo on his aggravated murder convictions, but not his assault convictions. As a result,

Leo is currently sentenced to 66 years in prison. Leo argues that this sentence is an unconstitutional

de facto life sentence and that he is entitled to have the mitigating factors of his youth considered

for his entire sentence. Leo contends that he suffered actual prejudice as a result of the trial court’s

refusal to revisit the overall sentence and asks that this court remand his case to the trial court for

a full resentencing, at which the court may consider how Leo’s youth affects his sentence as a

whole. The State argues that Leo’s sentence is not a de facto life sentence, as RCW 9.94A.730

affords Leo the opportunity for release after serving at least 20 years for his assault convictions,

and that resentencing is not required. No. 61187-2-II

We hold that Leo has demonstrated entitlement to relief. Leo is entitled, under our supreme

court’s holdings in State v. Gilbert1 and State v. Carter,2 to have the superior court consider his

entire sentence, not merely his sentences for aggravated murder. We further hold that RCW

9.94A.730 does not provide an adequate remedy in Leo’s case. Accordingly, we vacate Leo’s

sentence and remand for resentencing. On remand, the superior court, having already determined

that Leo’s crime was mitigated by his youthful characteristics, must consider how the mitigating

factors of Leo’s youth affected his sentence as a whole, and must have the discretion to adjust

Leo’s sentence accordingly.

FACTS

I. BACKGROUND AND LEO’S RESENTENCING

In 1998, 17-year-old Marvin Leo participated in a gang-related shooting, after which he

was charged with, and pleaded guilty to, five counts of aggravated first degree murder and five

counts of first degree assault, all with firearm enhancements. In 2000, the trial court sentenced Leo

to 5 terms of life without the possibility of parole (LWOP) for the aggravated murder counts, 5

terms of 100 months for the assault charges, and 10 firearm enhancements that each carried a term

of 60 months. Leo’s assault terms and their associated firearm enhancements were ordered to run

consecutive to each other and to Leo’s life sentence on the aggravated murders. In total, Leo was

sentenced to LWOP plus 1,100 months in prison.

1 193 Wn.2d 169, 438 P.3d 133 (2019). 2 3 Wn.3d 198, 548 P.3d 935 (2024).

2 No. 61187-2-II

Leo was resentenced in 2016, pursuant to the United States Supreme Court’s opinion in

Miller v. Alabama3 and Washington’s Miller-fix statutes (RCW 10.95.030 and .035). At his

resentencing hearing, Leo presented the expert testimony of Dr. Nathan Henry, a forensic

psychologist who evaluated Leo for his experiences in his youth and his risk of future violence.

Dr. Henry testified that Leo experienced a tumultuous childhood. Leo’s parents were violent with

each other, Leo’s father was an alcoholic, and Leo’s family moved from Hawai‘i to Tacoma when

Leo was in his early adolescence. Leo did not receive much support or guidance at home after

experiencing the culture shock of moving to Tacoma, as his parents separated shortly after the

move and his mother worked long hours. Leo started to become associated with a local gang at

about that time. According to Dr. Henry, a dysfunctional family life can lead a young person to

join a gang because they seek connection and support.

Dr. Henry also opined on Leo’s personality, demeanor, his rehabilitation efforts in prison,

and what bearing this context has on Leo’s likelihood of future violence. Dr. Henry found Leo to

be even-tempered, confident, and self-assured; he has not had a violent incident since 2001. Leo

has completed self-improvement courses while incarcerated, including a restorative therapy group,

an anger management course, a substance abuse course, and a cognitive behavioral life skills class.

All variables considered, Dr. Henry stated that Leo presents a low to moderate risk of future

violence and that Leo’s youth and difficult upbringing impacted his judgment when he participated

in the shooting.

At Leo’s resentencing hearing, the parties disputed the scope of the resentencing court’s

authority to adjust Leo’s sentence. The State contended that under RCW 10.35.030, the trial court

3 567 U.S. 460, 132 S. Ct. 2455, 183 L. Ed. 2d 407 (2012).

3 No. 61187-2-II

could not run Leo’s aggravated murder sentences concurrently. The State requested that the trial

court resentence Leo to 5 counts of 25 years to life each, to be served consecutively. Leo argued

that the trial court had authority to resentence him under either the sentencing reform act of 1981

(SRA), ch. 9.94A. RCW, as an exceptional downward sentence, because Leo’s existing sentence

constitutes excessive punishment, or under RCW 10.95.030. Leo asserted that imposing a new

consecutive sentence for each murder charge would violate RCW 10.95.030 as a de facto life

sentence. He requested a minimum sentence of 30 years to life, to be served concurrently. Leo

argued in his sentencing memorandum that the trial court should resentence him to 152 months for

each assault conviction, to be served concurrently with each other as well as with his aggravated

murder convictions, but neither party addressed Leo’s assault sentences during the resentencing

hearing. At the hearing, Leo expressed regret for his participation in the shooting and stated that

he has endeavored to improve himself and to be a positive influence for the younger men within

his correctional facility.

The trial court resentenced Leo on each of his aggravated murder convictions and firearm

enhancements to 40 years to life, to be served concurrently to each other and to the assault

convictions. The assault convictions, however, were not revisited on resentencing and the court

stated in the addendum to Leo’s judgment and sentence (J&S) that “[a]ll other terms and conditions

that are not modified by this addendum and which are set forth in the June 28, 2002, Judgment and

Sentence remain in full force and effect.” Clerk’s Papers (CP) at 440. As a result, the assault

sentences remained consecutive to each other, as well as consecutive to the firearm enhancements

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Related

In Re the Personal Restraint of Cook
792 P.2d 506 (Washington Supreme Court, 1990)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
State v. Houston-Sconiers
391 P.3d 409 (Washington Supreme Court, 2017)
State v. Gilbert
438 P.3d 133 (Washington Supreme Court, 2019)
In re Meippen
440 P.3d 978 (Washington Supreme Court, 2019)
State v. Haag
Washington Supreme Court, 2021
In re Pers. Restraint of Monschke
Washington Supreme Court, 2021
In re Pers. Restraint of Dodge
Washington Supreme Court, 2022

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