State Of Washington, V Charles v. Farnsworth, Jr.
43167-0
| Wash. Ct. App. | May 31, 2017Background
- Charles V. Farnsworth was convicted by a jury of first-degree robbery and sentenced as a persistent offender to life without release under RCW 9.94A.570 based on two prior "most serious" offenses.
- The sentencing court relied on a 1984 California conviction for vehicular manslaughter (abstract of judgment and charging documents) and a Washington first-degree robbery conviction.
- The State presented the California abstract showing conviction under former Cal. Penal Code § 192(c)(3) (vehicular manslaughter) and former Cal. Vehicle Code § 23153.
- Farnsworth challenged (1) whether the California conviction is legally comparable to a Washington "most serious" offense, (2) whether relying on prior convictions as sentencing facts violated jury and due process rights, (3) whether the persistent-offender scheme violated equal protection, and (4) whether the court improperly imposed LFOs.
- The Court of Appeals (on remand after Washington Supreme Court guidance) affirmed: it found legal comparability, upheld use of priors proved by preponderance, rejected the equal protection challenge, and held only mandatory LFOs were imposed.
Issues
| Issue | Plaintiff's Argument (Farnsworth) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Comparability of California vehicular manslaughter to Washington "most serious" offense | California offense not legally comparable to Washington vehicular homicide because causation/element differences | California statute is narrower (contains extra elements); any violation would also violate Washington statute so elements are legally comparable | Court held the offenses are legally comparable; no factual comparability analysis required |
| Use of prior convictions to increase sentence (jury/due process) | Sentencing facts (prior convictions) should be found by a jury beyond a reasonable doubt (Blakely/Apprendi) | The Constitution permits judicial factfinding for prior convictions; the only fact requiring jury proof beyond a reasonable doubt is the offense itself, not prior convictions | Court held relying on prior convictions proved by preponderance did not violate jury or due process rights |
| Equal protection challenge to persistent-offender scheme | Distinction between "elements" and "sentencing factors" arbitrarily discriminates and violates equal protection | Washington law permissibly treats prior convictions as sentencing factors for persistent-offender status, established by statute and precedent | Court rejected equal protection claim; precedent consistently upholds the distinction |
| Legal financial obligations (LFOs) and ability-to-pay finding | Trial court made a boilerplate finding of ability to pay LFOs without supporting record | Only mandatory (non-discretionary) LFOs were imposed, so ability-to-pay analysis not required | Court found only mandatory LFOs were imposed and denied relief |
Key Cases Cited
- State v. Thiefault, 160 Wn.2d 409 (2007) (two-part legal/factual comparability test for out-of-state convictions)
- Apprendi v. New Jersey, 530 U.S. 466 (2000) (facts increasing penalty beyond statutory maximum must be submitted to jury, except prior convictions)
- Blakely v. Washington, 542 U.S. 296 (2004) (Apprendi principle applied to sentencing guidelines)
- State v. Hughes, 154 Wn.2d 118 (2005) (judicial findings of prior convictions permissible for sentencing)
- State v. Ammons, 105 Wn.2d 175 (1986) (courts cannot go behind prior judgment/verdict to relitigate prior convictions)
- State v. Watson, 146 Wn.2d 947 (2002) (statutory interpretation: plain meaning and legislative intent)
- State v. Blazina, 182 Wn.2d 827 (2015) (appellate review of LFO ability-to-pay issues)