State v. Bluford, 393 P.3d 1219

Bluford was charged in multiple informations with nine counts: seven first-degree robberies and two sex-related offenses (one indecent liberties, one first-degree rape) arising from separate incidents over ~2 months in the Seattle area.
The State moved to join all charges under CrR 4.3(a); Bluford moved to sever the non-sex robberies; the trial court granted joinder and denied severance; Bluford did not renew severance at trial.
At trial Bluford was convicted on eight counts (acquitted on one robbery) and sentenced as a persistent offender to concurrent life terms without parole based in part on three out-of-state prior robbery convictions.
The Court of Appeals affirmed convictions but held the New Jersey prior was not comparable to a Washington "most serious offense," vacating the persistent-offender portion of the sentence; the State did not appeal that comparability conclusion.
Supreme Court granted review on joinder and persistent-offender issues, concluded the trial court abused its discretion by joining all nine charges because the evidence was not cross-admissible (no unique modus operandi) and the risk of undue prejudice—especially from sexual-offense evidence—outweighed judicial economy; convictions reversed and remanded.

Issue	State's Argument	Bluford's Argument	Held
Whether pretrial joinder of all nine counts under CrR 4.3(a) was proper	Joinder is permissible if charges meet CrR 4.3(a); likelihood of prejudice is relevant only on a severance motion, not joinder	Joinder must be denied if it will cause undue prejudice; trial court must consider prejudice when deciding joinder	Court reaffirmed that trial courts must consider likelihood of undue prejudice when deciding joinder; joinder of all nine counts was an abuse of discretion and convictions reversed
Whether Bluford's New Jersey 2d-degree robbery conviction is legally comparable to a Washington most serious offense for RCW 9.94A.570 purposes	Submitted record supports comparability to NJ subsection involving threats/force	Record does not show which NJ subsection applied; underlying facts not reliably proved or admitted	Court affirmed Court of Appeals: State failed to prove legal comparability from the record; New Jersey conviction insufficient for persistent-offender treatment

State v. Thompson, 88 Wn.2d 518 (recognizes CrR 4.3 joinder analyzed like prior statute; trial court discretion in joinder)
State v. Brunn, 145 Wash. 435 (early authority requiring joinder not to prejudice defendant's substantial rights)
State v. Smith, 106 Wn.2d 772 (trial court must articulate joinder/severance analysis on the record)
State v. Russell, 125 Wn.2d 24 (factors for assessing undue prejudice and cross-admissibility)
State v. Bythrow, 114 Wn.2d 713 (discusses prejudicial effect of prior sexual-offense evidence and joinder considerations)
State v. Vy Thang, 145 Wn.2d 630 (modus operandi/cross-admissibility standard under ER 404(b))
State v. Laureano, 101 Wn.2d 745 (example of admitting other-act evidence where distinctive similarities amounted to signature)
State v. Foxhoven, 161 Wn.2d 168 (analysis of distinctive, signature-like similarities for admissibility)