Washington v. Hugdahl (Majority and Dissent)
Annotate this CaseIn January 2017, petitioner Jamie Hugdahl was the target of two controlled drug buys executed by a confidential informant in the vicinity of a Safeway parking lot in Ellensburg, Washington. Hugdahl was subsequently charged by an information in 2017, which was amended twice. All three versions of the information alleged four counts of delivery of a controlled substance in violation of RCW 69.50.401(1). Count I was based on the first delivery of heroin. Counts II, III, and IV arose out of the second delivery involving methamphetamine, alprazolam, and ecstasy. The issue this case presented for the Washington Supreme Court’s review concerned the adequacy of the charging document in alleging statutory sentence enhancements for delivering controlled substances within a protected zone under RCW 69.50.435(l)(c). The statutory sentence enhancement applied where a delivery of a controlled substance occurred within 1,000 feet of a school bus route stop. Hugdahl's information alleged that she delivered controlled substances "within one thousand feet of a school bus route.'" Hugdahl first challenged the adequacy of the information on appeal, and a divided Court of Appeals affirmed finding that the information provided constitutionally adequate notice of the enhancement. The Supreme Court, however, reversed, finding that the charging document omitted the facts necessary to charge the statutory enhancement. The sentencing enhancement was vacated and the matter remanded for resentencing.
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