In oral argument, the Department of Corrections told the court that McBride’s juvenile first‑degree child‑molestation convictions (committed under age 16) cannot serve as predicates for an indeterminate sentence under RCW 9.94A.507; the state urged affirmance, and the bench pressed both sides on statutory construction.

Division 3 judges questioned whether 'tolling' in RCW 74.20A.055(2) requires the Department to begin location efforts before the 60-day deadline or whether post-deadline efforts can restore reimbursement rights; a written decision was reserved.