Washington v. Blair (Majority and Concurrence)
Annotate this CaseWashington State charged Christopher Blair with one count of theft of a motor vehicle, a Ford truck, that Blair purportedly stole in October 2011. Pursuant to that charge, he entered a drug court personal recovery program. Blair was terminated from the program in 2015. According to the record, Blair had five prior felony convictions in Washington, including second degree theft, second degree burglary, possession of a stolen vehicle, and two counts of theft of a motor vehicle at issue here. At sentencing, Blair argued for a "downward departure[from] the standard range" sought by the State and requested an exceptional sentence. Blair argued that although he had pleaded guilty to two counts of theft of a motor vehicle, both of those vehicles were snowmobiles, and therefore not "motor vehicles" as contemplated by RCW 9A.56.065. Blair asserted that his plea to the two counts were accordingly facially invalid. The Washington Supreme Court concluded Dennis should have alleged a constitutional defect of once of his prior convictions to challenge that conviction's validity for purposes of offender score calculation in an otherwise unrelated proceeding. The trial court declined to engage in statutory construction here and counted the two prior convictions at issue here for taking a motor vehicle. The Court of Appeals agreed with the trial court, and the Supreme Court affirmed.
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