Full Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON STATE OF WASHINGTON, No. 88680-1-I Respondent, DIVISION ONE v. UNPUBLISHED OPINION B.F.A-H, II, Appellant. SMITH, J. — B.F.A-H., a teenage girl, pleaded guilty in juvenile court to theft in the third degree for shoplifting two items of makeup from a department store. B.F.A-H. had a self-reported history of drug and alcohol use and numerous suicide attempts. The trial court declined to impose a mental health alternative sentence and imposed 12 months of supervision, including a random urinalysis (UA) monitoring requirement. B.F.A-H. appealed, claiming the court erred when it imposed the UA requirement because no nexus existed between UA testing and the crime committed. Because the court is allowed to impose UA conditions to monitor compliance with validly imposed statutory conditions or to promote rehabilitation and accountability of the juvenile, the trial court did not abuse its discretion. We affirm. FACTS In May 2024, the State charged B.F.A-H., a fifteen-year-old girl, with theft in the third degree for stealing makeup from a department store. B.F.A-H. No. 88680-1-I/2 pleaded guilty to the charge in July 2025. B.F.A-H. completed a mental health evaluation, which included an intake questionnaire. The evaluator noted that B.F.A-H. did not want to discuss substance use during their conversation, but, [p]er the intake questionnaire, filled out prior to the appointment, client noted she started drinking alcohol at age 13 and drinks every other day. Client reported in the questionnaire she has used Vodka and Tequila. Client mentioned using Xanax, Adderall, [Cannabis], Acid, Shrooms, Percocet[], Lean[1] and Cocaine in the questionnaire as well. Per the questionnaire, client started using [Cannabis] in 7th grade and tried the other substances or started using them in 10th grade. Based on B.F.A-H.’s mental health evaluation, the State and the probation counselor requested a substance use evaluation to determine whether B.F.A-H was eligible for a chemical dependency disposition alternative. The probation counselor noted that B.F.A-H. reported drug and alcohol use on her mental health evaluation, and B.F.A-H.’s previous suicide attempts included taking medication. Defense counsel objected, asserting a drug and alcohol evaluation was inappropriate because drugs were not involved with the crime charged, and probation conditions must be related to the offense. The court ultimately declined to order an evaluation. At the disposition hearing, the court imposed twelve months of supervision and declined a mental health alternative because it did not have a mental health evaluation recommending treatment. The court also imposed 16 hours of community service, which it noted could be completed by B.F.A-H. attending mental health treatment. The order required B.F.A-H. to continue to take any 1 Lean is a slang term for a drink that contains codeine, promethazine, soda, and sometimes alcohol. 2 No. 88680-1-I/3 prescribed medication and to engage in random UA testing “to verify whether or not [B.F.A-H.] is taking medication as prescribed.” Defense counsel noted that B.F.A-H. had not been prescribed any mental health medication. Probation stated its intention for the UAs was to monitor whether B.F.A-H was misusing substances as a coping mechanism. The court concluded the hearing by stating it was “going to find that there’s enough of a nexus . . . with regard to the community service hours and the medication and the mental health component, . . . so, I am going to order the random UAs.” In addition to the general conditions of community supervision, which included B.F.A-H. “refrain from committing new offenses,”2 the order required B.F.A-H. to “attend all mental health appointments and take medications as prescribed” and submit to random UA testing. B.F.A-H. appealed the imposition of the UA testing requirement. We find that the court did not abuse its discretion by imposing conditions that enable it to monitor other supervision conditions and that support rehabilitation. ANALYSIS B.F.A-H. contends the juvenile court erred when it imposed the UA condition because no nexus existed between UA testing and the crime charged. Because the court has authority to impose conditions that enable it to monitor other supervision conditions and that promote the rehabilitation of juveniles, it did not abuse its discretion to require B.F.A-H. to engage in random UA testing. 2 The condition included a prohibition on the possession and use of alcohol and non-prescribed controlled substances. 3 No. 88680-1-I/4 We review a juvenile court’s conditions of supervision for abuse of discretion.3 State v. J.H.-M., 28 Wn. App. 2d 757, 761, 538 P.3d 644 (2023). A court abuses its discretion if its decision is manifestly unreasonable. J.H.-M., 28 Wn. App 2d at 761. Juvenile courts have “wide latitude and discretion” when imposing conditions in a disposition order. State v. K.H.-H., 185 Wn.2d 745, 755, 374 P.3d 1141 (2016). Adjudication and disposition of juvenile defendants is controlled exclusively by the Juvenile Justice Act of 1977 (JJA), chapter 13.40 RCW. The JJA’s stated purposes, among others, are to hold youth accountable for their offenses, protect the public from criminal behavior, promote rehabilitation, and provide for necessary treatment and supervision. RCW 13.40.010. Unlike the Sentencing Reform Act of 1981, chapter 9.94A RCW, which determines adult sentencing and requires conditions of supervision to be related to the underlying offense, “the JJA permits juvenile courts to impose any conditions of supervision it deems necessary to meet the needs of the juvenile and to effectuate the rehabilitative and accountability goals of the JJA.” State v. S.D.H., 17 Wn. App. 2d 123, 131-32, 484 P.3d 538 (2021) (citing State v. H.E.J., 102 Wn. App. 84, 87, 9 P.3d 835 (2000)). In K.H.-H., the Supreme Court recognized the difference between adults and juveniles and held that “a juvenile court can impose and require reasonable 3 B.F.A-H. contends the standard of review is de novo and cites to State v. D.K.V., 16 Wn. App. 2d 938, 941, 483 P.3d 813 (2021), for support. But that case addresses the court’s authority to act when an offender is committed to Department of Children, Youth and Families; it does not discuss the court’s ability to impose conditions of supervision when it has authority to act. 4 No. 88680-1-I/5 conditions that are related to the crime of which the offender was convicted and that further the reformation and rehabilitation of the juvenile.” 185 Wn.2d at 755. The court went on to affirm the juvenile court’s decision to impose a letter of apology condition for the primary purpose of rehabilitation. K.H.-H., 185 Wn.2d at 745-55 (“The record in this case supports our conclusion that the juvenile court imposed the letter of apology condition for the purpose of rehabilitating K.H.-H.”) Recently, the Supreme Court clarified previous case law and confirmed UA testing conditions may be imposed to monitor compliance with validly imposed statutory conditions prohibiting alcohol and drug use, even when the UA testing was not crime related. State v. Nelson, 4 Wn.3d 482, 509, 565 P.3d 906 (2025). While the holding in Nelson pertained to adult community custody conditions, nothing in the opinion indicated the condition was imposed to have a punitive effect. Rather, the court noted the UA testing conditions “achieve the State’s compelling interest in monitoring Nelson’s compliance with his validly imposed community custody conditions prohibiting alcohol and drug use.”4 Nelson, 4 Wn.3d at 509. Two recent unpublished Court of Appeals opinions have taken the holdings from Nelson and K.H.-H. and applied them in cases involving juveniles and UA requirements. State v. S.J., No. 59322-0-ll, (Wash. Ct. App. July 29, 2025) (unpublished), https://www.courts.wa.gov/opinions/pdf/D2%2059322-0- 4 The Nelson court conducted an Article I, section 7 inquiry and held UA testing conditions were “narrowly tailored to achieve the State’s compelling interest in monitoring Nelson’s compliance with his validly imposed community custody conditions prohibiting alcohol and drug use.” 4 Wn.3d at 509. 5 No. 88680-1-I/6 II%20Unpublished%20Opinion.pdf, and State v. A.G., No. 88676-2-I, slip op. (Wash. Ct. App. June 15, 2026) (unpublished), https://www.courts.wa.gov/ opinions/pdf/886762.pdf. Both cases held conditions requiring juveniles to submit to UA testing to monitor compliance with statutorily authorized conditions are consistent with the accountability and rehabilitative purposes of the JJA. S.J., No. 59322-0-ll, slip op. at 22-24; A.G., No. 88676-2-I, slip op. at 3-6. B.F.A-H. claims these cases ignore the holding in K.H.-H. B.F.A-H. contends K.H.-H. stands for the proposition that, while juvenile conditions may be related to rehabilitation, they also must be crime related. This assertion is based on the following language in K.H.-H.: [W]e hold that a juvenile court can impose and require reasonable conditions that are related to the crime of which the offender was convicted and that further the reformation and rehabilitation of the juvenile. Under the broad authority and discretion given to juvenile courts to craft dispositions that adhere to the legislative intent of rehabilitation and crime-relatedness. 185 Wn.2d at 755. Contrary to B.F.A-H.’s assertion, nothing in the opinion indicates that the K.H.-H. court intended all conditions to be both rehabilitative and crime related. If that were the case, then many conditions ordered, such as firearm restrictions and mandatory school attendance, could not be imposed for crimes of theft, arson, etc., because the conditions are not directly related to those crimes. But even if the court in K.H.-H. did intend supervision conditions to be rehabilitative and crime related, the subsequent opinion in Nelson, clarified that conditions do not need to be crime related if they monitor compliance with conditions 6 No. 88680-1-I/7 prohibiting the use of alcohol and drugs. B.F.A-H. maintains Nelson is distinguishable because it addressed adults not juveniles, but the same analysis applies: the State has an interest in monitoring juvenile’s compliance with statutorily authorized conditions. Here, the court had authority to implement conditions that were not crime related. Like S.J. and A.G., the court imposed the UA condition to monitor B.F.A-H.’s compliance with the statutorily valid supervision conditions and to assist in B.F.A-H.’s rehabilitation. Both reasons are consistent with the accountability and rehabilitative purposes of the JAA. See RCW 13.40.010. Accordingly, the court did not abuse its discretion when it imposed a UA requirement. We affirm. WE CONCUR: 7