State of Washington v. Manuel Carrosco Mendoza Jr.

Court of Appeals of Washington·Decided January 22, 2026·No. 40797-7·Unpublished

Opinion

FILED JANUARY 22, 2026 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STATE OF WASHINGTON, ) No. 40797-7-III ) (consolidated with Respondent, ) No. 40806-0-III) ) v. ) ) UNPUBLISHED OPINION MANUEL CARROSCO MENDOZA JR, ) ) Appellant. )

MURPHY, J. — In this consolidated appeal, Manuel Carrosco Mendoza Jr.

appeals from separate convictions for felony violation of a no-contact order—domestic

violence. Carrosco Mendoza argues he was denied due process when the trial court

proceeded to a stipulated facts bench trial without first holding a contested drug court

termination hearing. He asks this court to reverse the convictions and remand his case

for a full drug court termination hearing. The State concedes there was a due process

violation and agrees with the relief requested by Carrosco Mendoza. We accept the

State’s concession, reverse the convictions and remand for further proceedings.

BACKGROUND

Because the parties agree on the underlying facts, we recite only those necessary

for resolution of this case. In January 2022, Carrosco Mendoza was charged in separate

causes of action with felony violation of a no-contact order—domestic violence. On

August 2, 2022, Carrosco Mendoza and the State entered into a drug court stipulation Nos. 40797-7-III; 40806-0-III State v. Carrosco Mendoza

and waiver agreement with the understanding that upon successful completion of the

program, the State would move for dismissal of the pending charges with prejudice. 1

However, if Carrosco Mendoza was terminated for cause from the program, then the

charges would be adjudicated through a stipulated facts bench trial.

Despite some minor sanctions, Carrosco Mendoza generally enjoyed

approximately one and one-half years of success in the drug court program. But in

February 2023, Carrosco Mendoza missed three scheduled urinalysis (UA) tests and

was then arrested and charged with fourth degree assault. Carrosco Mendoza received

a 28-day termination notice and was informed on March 7 that (1) to be considered

for removal from termination certain conditions must be met, and (2) any violations

while on termination notice would likely result in termination for cause from drug court.

On April 4, the court conducted a hearing and informed Carrosco Mendoza that the

termination notice period ended and he was in good standing.

However, at a review hearing two weeks later, the court informed Carrosco

Mendoza that he was being terminated from drug court, commenting:

I just don’t think you’re ready for this. You’ve collected some new charges. You’ve missed a UA. During the time that you were on termination notice, there was a dilute UA. We didn’t find out about it until after, so that wouldn’t have counted against you. But the day after missing a UA we just don’t think you’re ready for this program right now. So I’m terminating

1 A drug court contract and order was entered on this same date.

2 Nos. 40797-7-III; 40806-0-III State v. Carrosco Mendoza

you for cause from drug court. However, you still can participate in treatment. Merit resources are still open for you. I’m still rooting for you. I think that you can move forward in this, but we just can’t move forward in drug court. . . . .... So you need to be in touch with your attorney right away. And I’ll be scheduling some hearings for you going forward from there as well.

Rep. of Proc. (Apr. 18, 2023) at 189-90. A standard termination order was entered

that did not include specific findings. Carrosco Mendoza was not informed during the

April 18 hearing or in the written order of his right to an evidentiary hearing to contest

his termination from drug court.

At a hearing held on May 22, 2023, a second termination order was entered that

included findings. Although the boilerplate language in the second termination order

listed that a termination hearing took place, the parties agree it is unclear from the record

that a termination hearing ever occurred.

Carrosco Mendoza’s case proceeded in criminal court. At a hearing on June 12,

2023, defense counsel requested a continuance to resolve questions about the difference

between a stipulated trial and a drug court termination hearing. The State represented to

the trial court that Carrosco Mendoza was terminated from drug court for cause, but

confirmed he had a right to contest that order. Carrosco Mendoza’s counsel affirmatively

answered that Carrosco Mendoza contested his termination from drug court and wanted a

hearing. The trial court scheduled a contested termination hearing for June 30.

3 Nos. 40797-7-III; 40806-0-III State v. Carrosco Mendoza

However, rather than proceed with the scheduled contested drug court termination

hearing, for the next year a series of continuances were granted as the parties were

negotiating a global plea deal for Carrosco Mendoza’s various pending charges, including

the two charged violations of a no-contact order. Confusingly, the various orders setting

the case schedule inconsistently refer to the pending case hearings as stipulated trials,

revocation hearings, and drug court termination hearings. In at least one hearing, the State

represented that Carrosco Mendoza had been terminated from drug court, and a stipulated

bench trial was pending. However, no specific mention of a drug court termination

hearing was made during this time period. Instead, the hearing was continued as the

parties negotiated how to proceed with the different charges.

A stipulated bench trial on the two charged violations of a no-contact order took

place on October 8, 2024. Carrosco Mendoza was found guilty of both charges and

sentenced to 60 months of confinement on each count, to run consecutively.

ANALYSIS

Carrosco Mendoza argues the trial court violated his procedural due process rights

when he was terminated from drug court because, although he was informed of the

reasons for termination and his right to a contested hearing, he was denied due process

when an evidentiary hearing to contest the termination from drug court did not occur.

The State concedes that there was a due process violation. We agree with the parties that

4 Nos. 40797-7-III; 40806-0-III State v. Carrosco Mendoza

because a contested drug court termination hearing did not take place, and there are no

findings in the record to establish that the State met its burden by a preponderance of the

evidence in support of termination, Carrosco Mendoza’s due process rights were violated.

Our federal and state constitutions guarantee a criminal defendant the right to due

process of the law. U.S. CONST. amend. XIV; WASH. CONST. art. I, § 3. Procedural due

process requires an individual receive notice of the deprivation of a protected interest and

a meaningful opportunity to be heard. State v. Starkgraf, 29 Wn. App. 2d 30, 45, 539

P.3d 855 (2023).

“Due process guarantees apply in drug court revocation proceedings.” State v.

Harrison, 24 Wn. App. 2d 40, 48, 519 P.3d 244 (2022). A defendant terminated from

drug court has a right to an “‘independent determination that the deferred prosecution

agreement was violated, by a preponderance of the evidence with the burden of proof on

the State.’” Id. at 49 (quoting State v. Cassill-Skilton, 122 Wn. App. 652, 656, 94 P.3d

407 (2004)). Drug court participants must be informed before or during the termination

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State of Washington v. Manuel Carrosco Mendoza Jr., (Wash. Ct. App. 2026).

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Related

State v. Cassill-Skilton
94 P.3d 407 (Court of Appeals of Washington, 2004)
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539 P.3d 855 (Court of Appeals of Washington, 2023)