Washington v. Griffin
Annotate this CaseThe question before the Supreme Court in this case was whether a fact-finding hearing of "rapid recidivism" was a "sentencing" hearing exempt from the state rules of evidence. After a bench trial, the superior court found Petitioner James Griffin guilty of residential burglary. At sentencing, the judge imposed an exception sentence above the standard range, finding the existence of the aggravating circumstance. In making its determination that the aggravating circumstance existed, the court relied on inadmissible hearsay from the trial. Petitioner appealed his exceptional sentence. Though the appellate court agreed with Petitioner that the trial court relied on inadmissible hearsay, it affirmed the exceptional sentence. Upon review, the Supreme Court reversed the appellate court, vacated the exceptional sentence and remanded the case for resentencing: "[o]n remand the trial court may receive evidence to justify imposition of the exceptional sentence, and the rules of evidence apply to [Petitioner's] resentencing."
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