State v. Blair, 421 P.3d 937

Christopher Blair was sentenced for theft of a motor vehicle; at sentencing the State relied on five prior felonies, including two earlier convictions labeled "theft of a motor vehicle."
Blair argued those two priors were convictions for stealing snowmobiles and thus not "motor vehicles" under RCW 9A.56.065, seeking a lower offender score and an exceptional sentence.
The sentencing court declined to reexamine the prior convictions' statutory validity on the merits, ruling Blair had to use postconviction relief avenues; the court treated the priors as valid for offender score calculation.
The Court of Appeals affirmed on procedural grounds, concluding resolving Blair's claim would require statutory construction beyond the four-corners review of the prior judgments.
The Supreme Court granted review and addressed whether a sentencing court may engage in statutory interpretation to determine facial invalidity of prior convictions used in offender score calculation, and whether snowmobiles fall within RCW 9A.56.065.
The Supreme Court affirmed the Court of Appeals on procedural grounds: a sentencing court may not revisit prior convictions at sentencing unless the prior conviction is alleged to be constitutionally invalid on its face; it did not reach the snowmobile statutory issue.

Issue	Blair's Argument	State's Argument	Held
May a sentencing court, in calculating offender score, go beyond the judgment and engage in statutory interpretation to determine whether a prior conviction is facially invalid?	Trial court may consider related plea documents and perform statutory interpretation at sentencing to show the prior convictions are facially invalid (e.g., snowmobile vs motor vehicle).	Permitting statutory review at sentencing would create mini-trials, undermine finality, and is improper; defendant must use postconviction remedies unless the prior conviction is constitutionally invalid on its face.	Held: No. A sentencing court may remove a prior conviction from scoring only if the conviction is shown to be constitutionally invalid on its face; it should generally be limited to face-of-document review and not engage in broader statutory construction at sentencing.
Was Blair entitled to have his offender score reduced because his prior TMV convictions actually involved snowmobiles (i.e., whether RCW 9A.56.065 applies to snowmobiles)?	Snowmobiles are not "motor vehicles" under RCW 9A.56.065, so the prior convictions are facially invalid and should not count.	Resolving that statutory question would require construction beyond face-of-judgment review and thus is not proper at sentencing.	Held: Court did not reach the statutory issue because it affirmed on procedural grounds (need to allege constitutional facial invalidity to challenge priors at sentencing).

State v. Ammons, 105 Wash.2d 175 (discusses that prior convictions constitutionally invalid on their face may not be used to enhance current sentence)
State v. Irish, 173 Wash.2d 787 (reiterates that defendants may not generally contest prior convictions at subsequent sentencing and must use postconviction remedies)
In re Pers. Restraint of Coats, 173 Wash.2d 123 (examines facial invalidity in PRP context and scope of documents that may show facial invalidity)
In re Pers. Restraint of Thompson, 141 Wash.2d 712 (addresses what it means for a judgment and sentence to be valid on its face)
State v. Blazina, 182 Wash.2d 827 (discusses sentencing error exception and when sentencing objections preserve issues)
State v. Ford, 137 Wash.2d 472 (addresses preservation of sentencing objections and appellate review)