State v. Conover, 183 Wash. 2d 706

Conover was convicted on three counts of delivering heroin within 1,000 feet of a school bus route stop.
The trial court imposed 48-month base sentences on each delivery count, to run concurrently with each other.
It also imposed three 24-month school bus route stop enhancements, one per count, and ran them consecutively to the corresponding base sentences and to each other.
The total sentence was 120 months of confinement (base sentences concurrent, enhancements consecutive).
Conover appealed, challenging the calculation of his offender score and the consecutive treatment of enhancements.
The Supreme Court addressed whether RCW 9.94A.533(6) requires enhancements on multiple counts to run consecutively to each other.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RCW 9.94A.533(6) require enhancements on multiple counts to run consecutively to each other?	State argued enhancements must run consecutively to all other provisions, including other enhancements.	Conover argued the language is ambiguous and does not mandatorily require consecutive treatment across counts.	No; cannot force cross-count consecutivity; run to base sentences but not to each other.

In re Post Sentencing Review of Gutierrez, 146 Wn. App. 151 ((2008)) (context on concurrent vs. consecutive sentencing under RCW 9.94A.589)
State v. Charles, 135 Wn.2d 239 (1998) (first interpretation of firearm enhancements and concurrency)
State v. Jacobs, 154 Wn.2d 596 (2005) (drug-zone enhancement ambiguity; held for concurrency across counts pre-amendment)
State v. DeSantiago, 149 Wn.2d 402 (2003) (amended firearm/d deadly weapon enhancements to require consecutive service)
State v. Roberts, 117 Wn.2d 576 (1991) (statutory language differing across provisions; legislative intent discerned from context)