State of Washington v. Caleb J. Sharpe

546 P.3d 1046
CourtCourt of Appeals of Washington
DecidedApril 16, 2024
Docket39185-0
StatusPublished
Cited by2 cases

This text of 546 P.3d 1046 (State of Washington v. Caleb J. Sharpe) 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
State of Washington v. Caleb J. Sharpe, 546 P.3d 1046 (Wash. Ct. App. 2024).

Opinion

FILED APRIL 16, 2024 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) ) No. 39185-0-III Respondent, ) ) v. ) ) CALEB J. SHARPE, ) PUBLISHED OPINION ) Appellant. )

STAAB, J. — When Caleb Sharpe was 15 years old, he brought guns to his school

and opened fired on students and faculty. He eventually pleaded guilty to one count of

aggravated first degree murder, three counts of attempted first degree murder, and one

count of second degree assault against 48 victims. After an extensive sentencing hearing,

the trial court imposed an indeterminate sentence of 40 years to life for the conviction of

aggravated first degree murder. The court imposed a five-year firearm enhancement and

sentences on the other offenses concurrent to its sentence on the aggravated murder

charge.

On appeal, Sharpe raises several challenges to his sentence. First, he contends that

former RCW 10.95.030(3)(a)(i) (2015)1 required an exact sentence of 25 years to life for

1 The statute was amended effective July 2023. See LAWS OF 2015, ch. 134, § 5. Subsection (3)(a)(i) was renumbered and is now contained in RCW 10.95.030(2)(a)(i). No. 39185-0-III State v. Sharpe

defendants who are under the age of 16 at the time they commit this crime, and the

court’s sentence violated this statute. Second, Sharpe asserts that the firearm

enhancement under RCW 9.94A.533(3) does not apply to defendants who are under the

age of 16 when they commit the crime of aggravated first degree murder. Third, Sharpe

argues that a sentence of 40 years to life is an unconstitutional de facto life sentence.

Finally, he contends that his confession to police shortly after being arrested was

involuntary and the trial court erred by considering the confession during sentencing.

The State concedes that former RCW 10.95.030(3)(a)(i) requires a specific

sentence and the court’s sentence of 40 years to life violated this statute. Thus, the State

agrees that resentencing is required. The State disagrees with Sharpe’s analysis and

application of the firearm enhancement, and argues that it can still be applied consistent

with the sentence required by RCW 10.95.030(3)(a)(i) so long as Sharpe’s minimum term

does not exceed 25 years. Finally, the State contends that Sharpe waived any challenges

to the admissibility of his confession when he pleaded guilty.

We accept the State’s concession and hold that former RCW 10.95.030(3)(a)(i)

requires a trial court to impose the exact sentence of 25 years to life on a defendant who

was under the age of 16 when they committed the crime of aggravated first degree

murder. We decline to decide whether and in what manner the firearm enhancement can

be applied under these circumstances since the issue was not preserved and can be raised

at resentencing. Finally, we hold that Sharpe waived his right to challenge his confession

2 No. 39185-0-III State v. Sharpe

when he pleaded guilty. We grant the parties’ joint request to reverse Sharpe’s sentence

and remand for de novo resentencing. Since we remand for resentencing, we decline to

address Sharpe’s claim that a 40-year sentence amounted to a de facto life sentence.

BACKGROUND

When Caleb Sharpe was 15 years old, he opened fire against his fellow students at

Freeman High School, resulting in the death of one student and injuring three others.

Following the shooting, police apprehended Sharpe and he confessed to committing the

crimes. He explained that he had carefully planned every aspect of the attack and had

taken steps to prevent his plan from being discovered.

The State charged Sharpe with one count of aggravated first degree murder with a

firearm enhancement, three counts of attempted first degree murder, and 48 counts of

second degree assault.

The trial court held a CrR 3.5 hearing during which it determined that Sharpe’s

confession to police was admissible. Following the hearing, defense counsel filed several

motions for discretionary review with this court, including a challenge to the trial court’s

decision at the CrR 3.5 hearing and a challenge to a separate trial court decision

determining that Sharpe could not argue that he was not guilty by reason of insanity. See

Comm’r’s Ruling, No. 38337-7-III (Wash. Ct. App. Jan. 11, 2022).

Before this court decided any of the motions, Sharpe decided to plead guilty to

aggravated first degree murder with a firearm enhancement, three counts of attempted

3 No. 39185-0-III State v. Sharpe

first degree murder, and one count of second degree assault against 48 victims. The court

held a sentencing hearing over the course of six months, during which it listened to more

than 200 victim impact statements and expert testimony regarding the impact of Sharpe’s

youth on his crimes and culpability.

Both parties submitted sentencing memoranda to the court. Sharpe requested a

determinate sentence of 20 years on the first degree murder charge, to run concurrent

with the other sentences. In his memorandum, Sharpe indicated that the standard range

sentence under former RCW 10.95.030(3)(a)(i) for a person under the age of 16

convicted of aggravated first degree murder was 25 years to life. Sharpe also pointed out

that the standard range sentence under the sentencing guidelines would be 25 years to life

with a 5-year enhancement for the firearm, which could be run consecutive with any of

the sentences imposed on the other counts. Sharpe asserted that because he was a

juvenile, the trial court had discretion and could impose a sentence below the standard

range.

The State submitted a memorandum in which it provided a lengthy recitation of

the case law surrounding the sentencing of juveniles in the United States Supreme Court

and Washington courts. The State concluded by requesting an indeterminate sentence of

35 years to life, citing to former RCW 10.95.030(3)(a)(i). The State reasoned that the

hallmark features of youth did not diminish Sharpe’s culpability and “[e]ven when

accounting for and assigning more weight to Mr. Sharpe’s potential for rehabilitation,

4 No. 39185-0-III State v. Sharpe

Mr. Sharpe fails to show a downward departure is justified in this case.” Clerk’s Papers

(CP) at 2530.

At sentencing, the State characterized its requested sentence of 35 years as

accounting for Sharpe’s youth: “The state’s [sic] requested sentence of 35 years

minimum to life, under the ISRB[2] jurisdiction, is not only a significant mitigation from

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546 P.3d 1046, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-caleb-j-sharpe-washctapp-2024.