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According to a recent ruling by the WA State Supreme Court, an offender who receives the 3 strikes prison term (life without parole) can have a juvenile conviction count against them.

Court rules 6-3 in favor of juvenile crime inclusion

September 21st, according to The Center Square, the WA State Supreme Court ruled a juvenile offense can count towards the 3 strikes law.

Michael Scott Reynolds Jr. had challenged his 3 strikes conviction on the grounds his first offense was committed when he was 17.  In December of 2001, he attempted to rob a gas station with a BB gun. After initially being charged as a juvenile, it was moved to adult court and he was convicted of robbery.

Then in January of 2006, he and an accomplice broke into the apartment of a couple, held them hostage, and attempted to rob them. Reynolds pleaded guilty to 1st-degree robbery and burglary for his second strike. He was 21 at the time

Then finally, in February of 2018, he dragged a 33-year-old barista from the expresso stand where she was working, and attempted to rape her using a knife. He was convicted of 1st-degree robbery, and 2nd-degree attempted rape. The King County trial judge said he was a "persistent" offender and he was given the 3-strikes life without parole sentence.

His attorney tried to argue an offense committed as a juvenile cannot be used along with adult offenses for the 3 strikes. He also claimed it violated certain precedents and was cruel and unusual punishment.

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However, the Supreme Court disagreed, and despite a split 6-3 decision, said in cases such as this, Reynolds is a persistent offender, and the “people of Washington are entitled to condemn adults who chose to commit serious crimes after having twice been given a chance to reform themselves."  (The Center Square).

The court did not specifically if multiple juvenile offenses would count towards an adult 3-strikes sentence, but from this ruling, it appears (depending upon the crime) at least one can be considered.

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