State Of Washington, V Kristopher W. Erdelbrock, 49431-1

Kristopher Erdelbrock was a registered sex offender in Cowlitz County who, when registering on August 4, 2015, told Deputy Darrin Ullmann he had no place to live and was a transient.
Ullmann informed him that transients must report weekly to the county sheriff under RCW 9A.44.130(6)(b).
Erdelbrock failed to report on August 11, 18, and 25; he was charged with failing to register as a sex offender.
He stipulated that his criminal history required registration and waived a jury trial; the court convicted him after a bench trial.
At sentencing the court imposed mandatory legal financial obligations (LFOs): victim penalty assessment, criminal filing fee, and DNA collection fee.
Erdelbrock appealed, arguing (1) the corpus delicti rule barred admission of his statement that he lacked a fixed residence and (2) the court erred by imposing LFOs without assessing his ability to pay. The Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether corpus delicti prevents using Erdelbrock’s pre-offense statement that he had no place to live	State: statement admissible because it was made before the charged offense; supports finding of transient status	Erdelbrock: his statement is a self-incriminating admission and corpus delicti requires independent corroboration	Court: corpus delicti does not apply to statements made before commission of the offense; statement admissible
Sufficiency of evidence that Erdelbrock lacked a fixed residence and thus had weekly-reporting duty	State: Ullmann’s testimony and failure to sign in on three dates suffice	Erdelbrock: without corroboration of his statement, State failed to prove lack of fixed residence	Court: viewing evidence in State’s favor, a rational trier could find he was transient and failed to report; conviction supported
Whether mandatory LFOs may be imposed without an ability-to-pay inquiry	State: the challenged fees are mandatory LFOs that do not require ability-to-pay findings	Erdelbrock: court erred by imposing LFOs without assessing ability to pay	Court: fees are mandatory by statute; courts lack discretion to waive them for indigence; imposition proper
Whether appellate costs should be precluded	Erdelbrock: asks court not to award appellate costs	State: does not concede it will forgo costs	Court: declines to rule; appellate commissioner will resolve any cost bill under RAP 14.2

State v. Green, 182 Wn. App. 133 (corpus delicti rule requires corroboration for convictions based solely on defendant statements)
State v. Dow, 168 Wn.2d 243 (defendant’s statement alone insufficient absent corroboration)
State v. Witherspoon, 171 Wn. App. 271 (corpus delicti rule not applicable to statements made before or during the commission of the crime)
State v. Pietrzak, 110 Wn. App. 670 (pre-offense statements are not treated as confessions for corpus delicti purposes)
State v. Homan, 181 Wn.2d 102 (sufficiency-of-the-evidence standard: view evidence in light most favorable to the State)
State v. Lundy, 176 Wn. App. 96 (distinguishing mandatory and discretionary LFOs; mandatory LFOs may be imposed without an ability-to-pay inquiry)
State v. Clark, 191 Wn. App. 369 (identifying the victim penalty assessment and criminal filing fee as mandatory LFOs)
State v. Mathers, 193 Wn. App. 913 (confirming mandatory nature of certain LFOs)