In re Pers. Restraint of Eastmond
Annotate this CasePetitioner James Eastmond was convicted of first degree robbery and first degree burglary. At sentencing, the trial court imposed an enhancement on Petitioner's sentence, based on the jury's determination that he was armed with a deadly weapon. While Petitioner's case was pending, the Supreme Court had decided "Washington v. Recuenco (110P.3d 188 (2005)) in which the Court recognized that sentences like Petitioner's violated the Sixth Amendment to the federal constitution. Petitioner then brought a personal restraint petition to challenge the firearm enhancement. The issue presented to the Supreme Court was whether in these circumstances prejudice could be conclusively presumed on collateral review, or whether Petitioner needed to demonstrate actual prejudice. Upon review of the matter, the Supreme Court concluded that the rule announced in "Washington v. Williams-Walker (225 P.3d 913 (2010) did not apply retroactively, and as such, Petitioner needed to demonstrate actual prejudice. Because he had not done so, the Court dismissed his petition.
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