State Of Washington, V Joseph John Baza, 48541-9

In July 2015 police forced entry to a hotel room and found the victim bleeding and unconscious with Joseph J. Baza standing over her; the victim reported Baza strangled and repeatedly beat her and said "You will die."
Baza was subject to an existing no-contact order (VNCO) for the victim.
Baza pleaded guilty (Alford plea) to second degree assault (strangulation), felony harassment (knowingly threatening bodily injury), and felony violation of a no-contact order.
At sentencing the State argued the offenses were not the "same criminal conduct" under former RCW 9.94A.589(1)(a); Baza argued they were the same criminal conduct based on an objective intent analysis.
The trial court, relying in part on State v. Mandanas, found the convictions did not constitute the same criminal conduct and counted each offense separately for offender-score calculation.
On appeal Baza challenged the same-criminal-conduct determination and contended the court had applied the wrong (double jeopardy) analysis; the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the convictions constitute "same criminal conduct" under former RCW 9.94A.589(1)(a)	State: statutory intents differ for VNCO, harassment, and assault, so not same conduct	Baza: objective intent shows one common intent; offenses should be same conduct	Held: Offenses have distinct statutory intents; not same criminal conduct; counted separately
Whether the sentencing court applied only double jeopardy analysis and thus a remand is required	State: court considered statutory intent and Mandanas, and prosecution argued distinct intents	Baza: court "exclusively" applied double jeopardy analysis and erred	Held: Record shows court considered same-criminal-conduct analysis (and Mandanas); no remand needed
Whether Chenoweth's statutory-intent approach should govern over prior objective-intent tests	State: follow Chenoweth statutory-intent framework	Baza: Chenoweth inapplicable; objective-intent test should apply	Held: Court follows Chenoweth; statutory-intent analysis controls

State v. Chenoweth, 185 Wn.2d 218 (2016) (directs focus on statutory intent to determine "same criminal conduct")
State v. Graciano, 176 Wn.2d 531 (2013) (standard for appellate review of same-criminal-conduct determinations)
State v. Mandanas, 163 Wn. App. 712 (2011) (double jeopardy/same-conduct discussion relied on by sentencing court)
State v. Reed, 168 Wn. App. 553 (2012) (assault-by-strangulation requires intentional assault)
State v. Porter, 133 Wn.2d 177 (1997) (narrow construction of same-criminal-conduct doctrine)