State v. Meade

¶1 Forrest C. Meade, a juvenile, appeals the trial court’s manifest injustice disposition. We hold that sufficient evidence supports the manifest injustice decision, which the trial court found by the “clear and convincing” standard that is equivalent to “beyond a reasonable doubt” under State v. Rhodes, 92 Wn.2d 755, 760, 600 P.2d 1264 (1979), overruled on other grounds by State v. Baldwin, 150 Wn.2d 448, 461, 78 P.3d 1005 (2003). And we hold, based on State v. Schaaf, 109 Wn.2d 1, 743 P.2d 240 (1987), that the United States Supreme Court’s decision in Blakely v. Washington1 does not entitle…