Washington v. Friedlund (Majority)
Annotate this CaseThis consolidated appeal consisted of two criminal cases. In each case, the jury convicted the defendant and found that aggravating circumstances were present. At sentencing, the trial courts deviated from the standard sentencing range and imposed exceptional sentences. While both trial courts explained on the record their reasons for deviating from the standard range, neither court entered written findings as required by statute. Both sentences were affirmed by the Court of Appeals in unpublished opinions. The issue these cases presented for the Supreme Court's review was whether an on-the-record oral ruling could substitute for written findings when a trial court imposes an exceptional sentence. After review, the Supreme Court concluded that oral findings do not satisfy the requirements of the Sentencing Reform Act of 1981. The cases were remanded for entry of written findings of fact and conclusions of law.
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