State of Washington v. Freddy Raul Sanchez-Benitez
40139-1
Wash. Ct. App.May 29, 2025Background
- Freddy Sanchez-Benitez was convicted of first-degree robbery in 2009, sentenced to prison, community custody, and ordered to pay $2,047.28 in legal financial obligations (LFOs).
- In November 2023, Sanchez-Benitez sought a certificate of discharge despite owing an outstanding balance on his LFOs.
- The trial court denied his motion for a certificate of discharge, citing his unpaid LFOs.
- Sanchez-Benitez appealed, arguing the trial court erred in denying his motion, primarily due to his indigency and inability to pay LFOs.
- He had not petitioned for remission or modification of his LFOs under RCW 10.01.160(4).
Issues
| Issue | Sanchez-Benitez's Argument | State's Argument or Court's Analysis | Held |
|---|---|---|---|
| Did the trial court err in denying a certificate of discharge due to unpaid LFOs? | He is indigent and unable to pay, so the LFOs should not bar discharge. | State law requires all sentence conditions be met, including LFO payment, unless modified by court order. | No error; denial affirmed. |
| Is indigency alone a sufficient reason to grant a certificate of discharge with unpaid LFOs? | Court should consider hardship from inability to pay LFOs. | Relief for inability to pay is available but must be sought through a specific statutory process (RCW 10.01.160(4)). | Indigency does not excuse requirement unless proper petition is filed. |
| Has Sanchez-Benitez availed himself of legal remedies for LFO modification or remission? | N/A | He has not petitioned for remission or modification as provided by law. | No relief without following statutory process. |
| Can Sanchez-Benitez file for discharge in the future? | N/A | He may file again if he pays or has LFOs remitted per statute. | Yes, upon full payment or remission of LFOs. |
Key Cases Cited
- Stuckey v. Dep’t of Lab. & Indus., 129 Wn.2d 289 (Wash. 1996) (statutory interpretation standard of review is de novo)
- Rozner v. City of Bellevue, 116 Wn.2d 342 (Wash. 1991) (court seeks intent of Legislature in statutory construction)
- Berger v. Sonneland, 144 Wn.2d 91 (Wash. 2001) (statute is ambiguous only if it can reasonably be interpreted in two or more ways)
- State v. Gossage, 165 Wn.2d 1 (Wash. 2008) (requirements for certificates of discharge from sentence)
- State v. Johnson, 148 Wn. App. 33 (Wash. Ct. App. 2008) (sentencing court's authority in issuing certificates of discharge)
- State v. Donaghe, 172 Wn.2d 253 (Wash. 2011) (court can deny discharge if sentence terms unmet)