The Washington Supreme Court unanimously ruled Sept. 25 that a mandatory life sentence without parole imposed on a 20-year-old offender in 1986 violates constitutional protections, granting relief to John H. Schoenhals after 39 years in prison.
In *In re Personal Restraint of Schoenhals* (Wash. 2025), the state's highest court held that Schoenhals' personal restraint petition was timely and should be granted because his 1986 mandatory life without parole sentence for aggravated first degree murder committed at age 20 is unconstitutional. The unanimous decision represents a significant development in how courts evaluate mandatory sentencing for young adult offenders.
The court's ruling builds on its 2021 decision in *In re Personal Restraint of Monschke*, which announced new substantive constitutional rules regarding lengthy sentences for young offenders. The *Monschke* decision established precedent that meets the "significant change in the law" exception to Washington's one-year time bar on collateral relief, allowing Schoenhals to challenge his decades-old sentence.
Schoenhals received his mandatory life without parole sentence in 1986 for aggravated first degree murder. At the time of the offense, he was 20 years old. The mandatory nature of the sentence meant the trial court had no discretion to consider his youth or other mitigating factors when imposing the life term.
The Supreme Court's opinion reveals that while all nine justices agreed on the outcome, they differed in their legal reasoning. The lead opinion, authored by four justices including Whitener, González, Montoya-Lewis, and Mungia, relied heavily on the constitutional framework established in *Monschke*. This plurality approach suggests there may have been additional concurring opinions offering alternative rationales for the same conclusion.
The *Monschke* precedent has proven pivotal in challenging mandatory life sentences for young adult offenders in Washington. That 2021 plurality decision recognized that emerging scientific understanding of brain development and decision-making capacity in young adults creates constitutional concerns about mandatory life sentences imposed without consideration of age-related factors.
The constitutional challenge to Schoenhals' sentence reflects broader national trends questioning the appropriateness of mandatory life without parole sentences, particularly for offenders who committed crimes as young adults. Courts increasingly recognize that individuals in their early twenties share many of the developmental characteristics that make juvenile offenders less culpable than fully mature adults.
Washington's decision aligns with evolving Supreme Court jurisprudence on juvenile and young adult sentencing. While the U.S. Supreme Court has not yet extended its juvenile sentencing protections to young adults, several state courts have begun recognizing constitutional problems with mandatory life sentences for offenders in their late teens and early twenties.
The personal restraint petition process in Washington allows individuals to challenge their convictions or sentences on constitutional grounds, even years after their cases concluded. Typically, such petitions must be filed within one year of the conviction becoming final. However, exceptions exist for cases involving significant changes in the law, which the court found applicable here.
The timing of Schoenhals' petition, filed nearly four decades after his sentencing, would normally bar relief under Washington's statute of limitations. However, the court determined that the *Monschke* decision created a substantive constitutional rule that applies retroactively, providing an exception to the time bar.
The court's unanimous agreement on granting relief, despite differences in reasoning, suggests strong consensus that mandatory life without parole sentences for 20-year-old offenders raise serious constitutional concerns. This consensus may influence how trial courts approach sentencing young adult offenders in future cases.
The decision does not automatically release Schoenhals from prison. Instead, it invalidates his current sentence and will likely require resentencing proceedings where a court can consider his age at the time of the offense and other relevant factors. The new sentence could potentially include parole eligibility, though the specific outcome will depend on the resentencing proceedings.
The ruling may have implications for other Washington inmates serving mandatory life sentences imposed for crimes committed as young adults. Those with similar circumstances may now have grounds to file their own personal restraint petitions, potentially affecting dozens of cases throughout the state.
Legal experts note that the decision reflects changing understanding of neuroscience and developmental psychology, which increasingly shows that brain development continues into the mid-twenties. This scientific evidence has influenced courts to reconsider the appropriateness of treating young adult offenders exactly like fully mature adults for sentencing purposes.
The Washington Supreme Court's decision represents the latest development in ongoing national discussions about criminal justice reform, particularly regarding lengthy sentences imposed on young offenders. As courts continue grappling with these issues, the Schoenhals ruling may serve as precedent for similar challenges in other jurisdictions.