The following excerpt is from Toomey v. Clark, 876 F.2d 1433 (9th Cir. 1989):
1 In Washington, a juvenile court after a hearing may transfer a case for adult criminal prosecution upon finding that the declination would be in the best interest of the juvenile or the public. Wash.Rev.Code Ann. Sec. 13.40.110(2) (West Supp.1989). Its decision to decline jurisdiction is discretionary and subject to reversal only if exercised upon a ground clearly untenable or manifestly unreasonable. Toomey, 690 P.2d at 1178. It, however, must comply with certain due process requirements. Kent v. United States, 383 U.S. 541, 553, 86 S.Ct. 1045, 1053, 16 L.Ed.2d 84 (1966); State v. Holland, 98 Wash.2d 507, 515-16, 656 P.2d 1056, 1061-62 (1983) (list of factors a juvenile court should consider before waiving jurisdiction).
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