State v. Luna, 2025 Wash. LEXIS 579 (Wa. 2025)

The Supreme Court of Washington vacated a conviction for second-degree murder, finding that the 16-year-old defendant’s waiver of rights was invalid, considering her age, recent head trauma, and lack of experience with the police. The court stated in relevant part:

“Luna challenges several evidentiary rulings and argues that the court should have applied newly enacted RCW 13.40.740 to exclude evidence from the interrogation. These rulings required the trial court to apply centuries-old legal doctrines—waiver of constitutional rights, res gestae, and the foundation requirement for evidence—in a modern context, involving two things the law has not always adequately understood: young people and social media. Courts must meaningfully consider a defendant’s youth when assessing whether they understood their constitutional rights well enough to waive those rights and proceed with an interrogation. Courts must also examine social media evidence in the context in which it arises and in light of the purpose for which it is proffered.

We hold that the court here erred in applying these principles. While RCW 13.40.740 does not apply, Luna did not validly waive her right to silence, and evidence from her interrogation should not have been admitted. Further, several evidentiary rulings concerning social media evidence undermined the fairness of the trial and the soundness of the verdict. We therefore vacate the jury verdict and remand for further proceedings consistent with this opinion.”