267 P.3d 324
Wash.2011Background
- In 1995, Coats pled guilty to conspiracy to murder, conspiracy to rob, and robbery; standard range sentence was 20 years; judgment misstated max for conspiracy to rob as life.
- In 1994, at age 14, Coats and two friends attempted to kill a man and steal his BMW; victim escaped from trunk after misstep.
- Initially charged with six counts; juvenile court declined jurisdiction; Coats pled guilty to three counts, others dropped, with standard range recommendation.
- Judgment and sentence incorrectly stated the maximum for conspiracy to commit first-degree robbery as life; actual max was 10 years; other two counts remained max life.
- Fourteen years later, Coats filed a personal restraint petition arguing the facial error made his plea invalid; Court of Appeals dismissed.
- The Supreme Court granted review to decide facial validity of the judgment and whether Coats could withdraw his plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the judgment facially invalid under RCW 10.73.090(1)? | Coats argues the misstatement renders the judgment invalid on its face. | State argues the error does not show authority exceeded and the judgment is not facially invalid. | Judgment not facially invalid; time bar applies. |
| Does facial invalidity avoid the one-year time bar for all claims? | Coats contends facial invalidity opens the door to untimely claims, including his guilty plea. | State resists expanding the gateway beyond the invalidity claim. | No, invalidity does not automatically toll for all claims; limited remedy applies. |
| Did the misstatement affect the voluntariness of the guilty plea? | Coats asserts misinformation about direct consequences undermines voluntariness. | State argues plea documents may be examined for facial validity but do not render the plea involuntary. | Guilty-plea voluntariness not saved by facial invalidity; subject to separate review if timely. |
| What is the proper remedy for an invalid judgment and sentence? | Coats seeks withdrawal of plea or other relief due to invalid judgment. | State urges correcting the erroneous judgment only; no broad relief | Remedy is correction of the judgment; petition denied beyond the specific invalidity. |
Key Cases Cited
- In re Pers. Restraint of McKiearnan, 165 Wn.2d 777 (2009) (misstatement of offender maximum; facial validity discussed)
- State v. Hinton, 152 Wn.2d 853 (2004) (convicted of nonexistent crime; facial invalidity discussed)
- Stoudmire, 141 Wn.2d 342 (2000) (facial invalidity based on statute of limitations; remanded)
- Bradley, 165 Wn.2d 934 (2009) (prejudice discussion; package-deal plea context)
- Runyan, 121 Wn.2d 432 (1993) (suspension clause; time bar preserved with exceptions)
- Goodwin, 146 Wn.2d 861 (2002) (offender score and authority over sentences; facial validity context)