State Of Washington v. Anthony Edwards
47235-0
| Wash. Ct. App. | Nov 1, 2016Background
- Anthony Lee Edwards pled guilty on Feb. 11, 2015; sentencing occurred the same day.
- The State requested and the court imposed discretionary legal financial obligations (LFOs), including $400 for court-appointed attorney fees/defense costs and $500 to the Department of Assigned Counsel.
- The sentencing court did not make an on-the-record, individualized inquiry into Edwards’s current or future ability to pay before ordering discretionary LFOs.
- An order of indigency was entered on March 5, 2015 (after sentencing).
- Edwards did not object to the LFOs at sentencing and raised the issue for the first time on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sentencing court erred by imposing discretionary LFOs without an on-the-record inquiry into ability to pay | Edwards: court must conduct individualized inquiry into current and future ability to pay before imposing discretionary LFOs | State: (implicit) no timely objection below; issue forfeited absent exceptional circumstances | Court exercised RAP 2.5(a) discretion, held error; reversed discretionary LFOs and remanded for individualized inquiry |
| Whether appellate review is barred because Edwards failed to object at sentencing | Edwards: seeks review under RAP 2.5(a) despite no objection | State: forfeiture rule under Blazina/Duncan supports refusing review | Court exercised discretion to review under RAP 2.5(a) and reached merits |
| Whether the record’s boilerplate suffices for ability-to-pay inquiry | Edwards: boilerplate is insufficient; record must show individualized inquiry | State: (implicit) boilerplate acceptable if present | Court followed Blazina/Duncan: boilerplate insufficient; individualized inquiry required |
| Whether to address ineffective assistance claim tied to counsel's failure to object | Edwards: counsel ineffective for not objecting at sentencing | State: not reached due to primary error resolution | Court declined to reach ineffective assistance because it reversed and remanded on the LFO error |
Key Cases Cited
- State v. Blazina, 182 Wn.2d 827 (2015) (trial court must make individualized on-the-record inquiry into defendant’s ability to pay before imposing LFOs)
- State v. Duncan, 185 Wn.2d 430 (2016) (reaffirming Blazina’s requirement for individualized inquiry)
- City of Richland v. Wakefield, 380 P.3d 459 (Wash. 2016) (same principle that boilerplate findings are inadequate)