State Of Washington, V. Warren E. Ring, 81350-1

Warren Ring, a military veteran with PTSD-related delusions, fired a gun from his car at an SUV with two passengers, then called 911 and was arrested.
Charged with two counts of second-degree assault, each carrying a 36-month firearm enhancement under RCW 9.94A.533(3)(e).
Standard range for each assault was 12–14 months; with enhancements the presumptive range became 84–86 months.
Ring sought an exceptional downward sentence to 36 months total (arguing the court could reduce/run enhancements concurrently because his culpability was impaired by mental illness).
Trial court found Ring’s capacity was significantly impaired, imposed an exceptional downward term of 9 months concurrent for the assaults, but declined to reduce or run the two 36‑month firearm enhancements concurrently, resulting in 81 months total.
Ring appealed arguing (1) the court should have exercised discretion to reduce or run the enhancements concurrently under RCW 9.94A.533, and (2) mandatory firearm enhancements violate the Eighth Amendment when culpability is reduced by mental illness. The Court of Appeals affirmed.

Issue	Ring's Argument	State's Argument	Held
Whether the sentencing court had discretion under RCW 9.94A.533 to reduce or run firearm enhancements concurrently as part of an exceptional downward sentence	RCW 9.94A.533 does not preclude reducing or running enhancements concurrently; Mohamed treats enhancements as part of the standard range; any ambiguity invokes rule of lenity	Subsection 3(e) unambiguously makes firearm enhancements mandatory, to be served in total confinement and run consecutively; Brown controls	Court held sentencing court lacked discretion to reduce or run firearm enhancements concurrently; affirmed Brown and Mandefero applying mandatory/consecutive rule
Whether mandatory firearm enhancements violate the Eighth Amendment for offenders whose culpability is reduced by mental illness	Imposing mandatory consecutive enhancements on someone with diminished culpability due to mental illness is cruel and unusual; analogies to Houston‑Sconiers/Atkins support consideration of mental impairment	No national consensus rejects mandatory enhancements for mentally ill adults; precedents distinguishing juveniles and intellectual disability cases; Ring bears burden to show consensus	Court held Ring failed to show an Eighth Amendment violation; mandatory enhancements do not categorically violate the Eighth Amendment in this context

State v. Brown, 139 Wn.2d 20 (holding deadly‑weapon/firearm enhancements mandatory and not subject to exceptional downward deviation)
State v. Houston‑Sconiers, 188 Wn.2d 1 (permitting discretion for juvenile offenders to depart from mandatory enhancements)
State v. Mohamed, 187 Wn. App. 630 (discussing when an enhancement is part of the standard range and limits of waiving enhancements)
State v. McFarland, 189 Wn.2d 47 (allowing downward departure when consecutive firearm convictions produce a clearly excessive presumptive sentence)
In re Pers. Restraint of Mulholland, 161 Wn.2d 322 (permitting concurrent terms for serious violent offenses despite statutory consecutive requirement)
State v. Mandefero, 14 Wn. App. 2d 825 (applying Brown to adults and noting legislative acquiescence)
Graham v. Florida, 560 U.S. 48 (framework for categorical Eighth Amendment analysis regarding national consensus)
Atkins v. Virginia, 536 U.S. 304 (Eighth Amendment bars death penalty for intellectually disabled offenders)