Personal Restraint Petition of Jonathan Eldwon Parks

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
DIVISION II
In the Matter of the Personal Restraint of:
JONATHAN ELDWON PARKS,
No. 59661-0-II
UNPUBLISHED OPINION
Petitioner.
LEE, P.J. — In this personal restraint petition (PRP), Jonathan E. Parks challenges the
Indeterminate Sentencing Review Board’s (ISRB) decision finding him not releasable and adding
12 months to his minimum term. However, Parks’ PRP is now moot. Accordingly, we dismiss
Parks’ PRP.
FACTS
In 2003, Parks was convicted of second degree rape—domestic violence (DV), unlawful
imprisonment—DV, and second degree theft. Parks was sentenced to 126 months to life on the
second degree rape charge.
In 2021, the ISRB released Parks, but his release was revoked less than six months later.
In 2022, the ISRB found that Parks was not releasable and added 24 months to his minimum term.
Parks filed a PRP challenging the ISRB’s 2022 releasability decision. The ISRB decided
to hold a new releasability hearing to ensure that its decision complied with the requirements of In
re Personal Restraint of Dodge, 198 Wn.2d 826, 502 P.3d 349 (2022). Because the ISRB had
decided to hold a new releasability hearing, this court dismissed Parks’ PRP challenging the 2022
releasability decision.
Filed
Washington State
Court of Appeals
Division Two
January 27, 2026

No. 59661-0-II
2
In May 2023, the ISRB held a releasability hearing and determined that Parks was not
releasable. Parks filed this PRP challenging the ISRB’s 2023 releasability decision. In January
2025, this court appointed counsel and referred Parks’ PRP to a panel of judges for consideration.1
In February 2025, the ISRB held a releasability hearing and found Parks releasable. The
ISRB filed a motion to dismiss Parks’ PRP, which challenges the 2023 releasability decision, as
moot. A commissioner of this court ruled that the ISRB’s motion to dismiss should be considered
by a panel of judges.
ANALYSIS
We will dismiss a case if it is moot. RAP 18.9(c). “‘A case is moot if a court can no longer
provide effective relief.’” State v. Ross, 152 Wn.2d 220, 228, 95 P.3d 1225 (2004) (quoting State
v. Gentry, 125 Wn.2d 570, 616, 888 P.2d 1105, cert. denied, 516 U.S. 843 (1995)).
Following the ISRB’s 2025 releasability decision, we can no longer grant Parks effective
relief on his challenge to the ISRB’s 2023 releasability decision because the 2023 decision is no
longer restraining Parks. The only remedy available to Parks in this PRP is reversal of the ISRB’s
2023 releasability decision and remand for a new releasability hearing, which has already occurred.
See Dodge, 198 Wn.2d at 845. Because we cannot provide any effective relief on Parks’ challenge
to the ISRB’s 2023 releasability decision, Parks’ PRP is moot. Accordingly, we dismiss Parks’
PRP.
1 In April 2025, this court granted Parks’ motion to proceed as self-represented due to his
frustrations related to the delay in appointing counsel.

No. 59661-0-II
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A majority of the panel having determined that this opinion will not be printed in the
Washington Appellate Reports but will be filed for public record in accordance with RCW 2.06.040,
it is so ordered.
Lee, P.J.
We concur:
Glasgow, J.
Che, J.