State of Washington v. Terrenz R. Henderson, 34170-4

Hampton-Henderson was charged in a global resolution with unlawful possession of a firearm (2nd degree) and taking a motor vehicle without permission (2nd degree); he pled guilty on February 9, 2016.
The amended information misstated one crime date; the plea form listed an offender score of 9+.
The judgment and sentence set out a criminal history that, by the court’s own handwritten notations, suggested some prior convictions were gross misdemeanors or washed out, producing an offender score of 8.5 or 8 rather than 9.
At sentencing the court accepted the plea, found it knowingly and voluntarily entered, denied Hampton-Henderson’s motion to withdraw the plea, and imposed standard-range DOSA and non‑DOSA terms based on an offender score of 9.
On appeal the State conceded the offender score was miscalculated and asked for resentencing; Hampton-Henderson argued the miscalculation rendered his plea involuntary and sought withdrawal.
The Court of Appeals concluded the offender score was improperly calculated and, under controlling precedent, reversed and remanded with instructions to allow withdrawal of the guilty plea.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hampton-Henderson)	Held
Whether the trial court miscalculated the offender score	Offender score was miscalculated and case should be remanded for resentencing	Offender score was miscalculated (judgment shows at most 8.5 or 8) and that error afflicted the plea	Court agreed the score was miscalculated (should be 8), error present
Whether miscalculation of offender score requires withdrawal of guilty plea	Remand for resentencing (State implicitly concedes error but cites cases involving trials)	Miscalculation of offender score rendered plea involuntary; under Mendoza/King plea must be withdrawn	Court held miscalculation rendered plea involuntary and ordered reversal and remand to permit withdrawal of plea

State v. Mendoza, 157 Wn.2d 582 (2006) (guilty plea may be withdrawn when misinformation about direct consequences, including offender score, renders plea involuntary)
State v. King, 162 Wn. App. 234 (2011) (following Mendoza—miscalculated offender score requires withdrawal of plea)
State v. Tili, 148 Wn.2d 350 (2003) (offender score calculation reviewed de novo)
In re Personal Restraint of Johnson, 131 Wn.2d 558 (1997) (sentence imposed on miscalculated offender score is without statutory authority)
Boykin v. Alabama, 395 U.S. 238 (1969) (pleas must be knowing, voluntary, and intelligent)