State Of Washington, V Natrone D. Bostick, 49427-2

In May–June 2016, Natrone D. Bostick pled guilty to first‑degree kidnapping and first‑degree assault; plea form and colloquy show he understood rights waived and agreed to the State’s recommended 180‑month sentence.
The underlying facts: Bostick and a co‑defendant entered the victim’s home, tied the victim, threatened him with a pistol, assaulted him, demanded a safe combination, and stole property.
At sentencing the court imposed 180 months and $2,772.50 in legal financial obligations (LFOs), including $1,972.50 in discretionary attorney fees, after asking Bostick two brief questions about his ability to work post‑release.
Bostick appealed, arguing (among other things) the trial court failed to make a sufficient Blazina inquiry into his present and future ability to pay discretionary LFOs; he also filed a Statement of Additional Grounds (SAG) raising several collateral challenges.
The Court of Appeals affirmed the convictions, held the plea was knowing and voluntary, rejected the SAG claims, but reversed the discretionary LFOs and remanded for a proper Blazina inquiry.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Bostick)	Held
Adequacy of inquiry before imposing discretionary LFOs	Trial court’s brief questioning showed Bostick can work; sufficient to support imposition	Inquiry was limited to ability to work and failed to consider present/future resources, debts, incarceration, GR 34 indigency	Reversed: inquiry was insufficient under Blazina; remand for individualized inquiry
Voluntariness/knowledge of guilty plea	Plea form and colloquy show Bostick was informed and understood limited appeal rights and consecutive sentence risk	Plea was not knowing/voluntary because he wasn’t told of limited right to appeal	Affirmed: plea was knowing, voluntary, intelligent; Bostick retained certain limited challenges and initialed plea form
Sufficiency of charging basis for first‑degree kidnapping	Probable‑cause affidavit provided evidence of intent to rob, restraint (tying, threat) supporting kidnapping charge	Prosecutor lacked sufficient basis to charge kidnapping	Affirmed: affidavit supplied sufficient basis; prosecutor did not abuse charging discretion
Ineffective assistance of counsel	Counsel reviewed plea, sentencing recommendations, and plea form with client	Counsel failed to advise limited appeal rights, failed to challenge kidnapping charge, failed to advise about consecutive sentences	Rejected: presumption of effective assistance not overcome; claims meritless given plea colloquy and plea form initials

State v. Blazina, 182 Wn.2d 827 (trial court must inquire into defendant’s present and future ability to pay before imposing discretionary LFOs)
State v. Clark, 191 Wn. App. 369 (standard of review for LFO imposition)
State v. Weyrich, 163 Wn.2d 554 (guilty plea must be knowing, voluntary, and intelligent)
State v. McFarland, 127 Wn.2d 322 (two‑part ineffective assistance of counsel test)
State v. Robinson, 172 Wn.2d 783 (misinformation about sentencing consequences can invalidate plea)