State Of Washington, V. B.f.a-h., Ii
CourtCourt of Appeals of Washington
Date FiledNovember 9, 2026
Docket88680-1
StatusUnpublished
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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UNPUBLISHED OPINION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.
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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
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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:
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