State v. Scott

*1183*588¶ 1 This case addresses the adequacy of the parole remedy available under ROW 9.94A.730, the Miller1 "fix" statute. Consistent with the Supreme Court's decision in Montgomery v. Louisiana, --- U.S. ----, 136 S.Ct. 718, 193 L.Ed. 2d 599 (2016), we hold that RCW 9.94A.730 's parole provision is an adequate remedy for a Miller violation, rendering unnecessary the resentencing of a defendant who long ago received a de facto life sentence as a juvenile.

FACTS

¶ 2 Jai'Mar Scott was convicted by a jury in 1990 of first degree premeditated murder for killing his neighbor, a 78-year-old-woman who…