State of Washington v. Tyler Scott Fife, 34442-8

Background

Fife participated in burglaries with others and testified he acted under duress: the ring leader, Sean Dahlquist, threatened him with a knife and a gun; co-defendant corroborated this.
The jury rejected Fife’s duress defense and convicted him on all 13 counts.
At sentencing, Fife requested a downward (mitigated) exceptional sentence based on (1) duress/inducement and (2) lack of predisposition to commit crime.
The State argued the judge should not revisit the jury’s finding of no duress.
The trial court denied a downward departure, reasoning that the jury’s rejection of duress and the court’s belief that duress was not proven precluded a mitigated sentence; the court stated (incorrectly) that Fife would have to prove duress by “substantial and compelling” evidence.
The court did not address Fife’s separate argument that he lacked a predisposition and was induced to participate; Fife appealed the sentencing procedure, and the Court of Appeals remanded for resentencing.

Issues

Issue	Fife's Argument	State's Argument	Held
Whether a defendant may appeal a standard‑range sentence based on the sentencing procedure	Fife: may appeal procedural errors where court failed properly to consider an exceptional sentence request	State: RCW 9.94A.585 bars appeals of standard‑range sentences except limited statutory mandates	Court: Procedural challenge to sentencing consideration is reviewable; defendant entitled to have exceptional request considered
Whether a sentencing court may decline to consider duress because the jury rejected duress	Fife: court may independently consider duress for mitigation despite jury rejection	State: sentencing court should not revisit jury verdict	Court: Jury rejection does not automatically preclude court from considering mitigating duress; statute assumes incomplete defense and allows court consideration
Proper burden/evidentiary standard for proving mitigating circumstances at sentencing	Fife: duress for mitigation must be shown by preponderance of evidence under RCW 9.94A.535	State: (implicit) higher standard cited by court	Court: Trial court erred in requiring “substantial and compelling” evidence to prove duress; mitigation elements are proved by preponderance
Whether court must address alternative mitigation ground (lack of predisposition/inducement)	Fife: court failed to consider or rule on this distinct mitigating factor	State: court implicitly rejected it	Court: Error—trial court failed to address the inducement/no‑predisposition claim and must consider it on remand

Key Cases Cited

State v. Knight, 176 Wn. App. 936 (2013) (procedural challenges to sentencing consideration are reviewable)
State v. Grayson, 154 Wn.2d 333 (2005) (defendant entitled to request and have court actually consider exceptional sentence)
State v. Garcia Martinez, 88 Wn. App. 322 (1997) (appellate review available when court refused to exercise discretion or relied on impermissible grounds in sentencing)
State v. Parker, 132 Wn.2d 182 (1997) (appellate review permits correction when sentencing court acts outside statutory structure)
John Doe v. Washington State Patrol, 185 Wn.2d 363 (2016) (statutory interpretation avoids constructions that render portions meaningless)