State v. Irish, 272 P.3d 207

Irish and another man robbed a drug store in 2007; Irish was captured while fleeing, accomplice escaped.
A jury convicted Irish of one count of first degree robbery, three counts of second degree assault, one unlawful possession of a controlled substance, and one unlawful possession of a firearm.
The trial court merged one assault into the robbery; Irish's offender score included four 1998 convictions (two first degree robbery, two second degree assault) all on the same day and counted separately for current sentencing.
On remand, Irish argued the 1998 convictions should not be counted separately under same-conduct/ offender-score rules; Court of Appeals remanded, but treated the argument as unresolved.
At resentencing, the trial court again counted the 1998 convictions separately and imposed a high-end standard-range sentence.
Court of Appeals vacated the sentence, concluding the 1998 convictions may have violated double jeopardy and remanded for re-determination; State petitioned for review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 1998 convictions can be challenged for double jeopardy in current sentencing	Irish	Irish	No; double jeopardy challenge not required in current sentencing
Whether prior convictions used for offender score may be challenged for validity in current sentencing	State	Irish	State need not prove validity; Ammons control permits use without collateral challenge
Proper remedy when prior convictions are alleged to violate double jeopardy	State	Irish	If challenge is desired, pursue postconviction relief, e.g., personal restraint petition

State v. Ammons, 105 Wash.2d 175 (1986) (state need not prove validity of prior convictions for current offender-score consideration)