State v. Lamb, 285 P.3d 27

Lamb charged in 2009 with 3 theft of a firearm, 10 unlawful firearm possession, and 1 marijuana manufacture; predicate for firearm counts was Lamb's 1991 juvenile second degree burglary adjudication.
Lamb previously pleaded guilty as a juvenile to indecent liberties in 1987 and to second degree burglary in 1991; rights to firearm possession were not terminated at the time.
Legislature amended firearm prohibitions in 1992, 1994, and 1996, expanding to all firearms and to persons with certain juvenile or felony adjudications; Lamb never received notice of firearm-rights termination.
Lamb moved to withdraw his 1991 plea and vacate the juvenile adjudication; the trial court granted after a hearing, finding a manifest injustice.
The State timely appealed; the Court of Appeals reversed; on discretionary review, the Supreme Court retained all issues for decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Withdrawal of plea and vacation of adjudication	Lamb argues manifest injustice justifies postjudgment relief	State argues no proper CrR 7.8 standard applied	Abuse of discretion; needs CrR 7.8 standard, not CrR 4.2(f) alone.
Denial of State's motion to amend the information	State seeks amendment to base firearm counts on a different adjudication	Amendment may be denied under CrR 2.1(d) even without prejudice	Trial court did not abuse discretion; amendment permissible but preexisting standard applies.
Dismissal of unlawful firearm counts	Lamb argues no valid predicate after vacatur	Dismissal justified by lack of predicate	Dismissal was an abuse of discretion; predicate restored on reversal of vacatur; remand needed.

State v. Cadwallader, 155 Wn.2d 867 (Wash. 2005) (abuse of discretion standard for postjudgment withdrawal of plea)
State v. Marshall, 144 Wn.2d 266 (Wash. 2001) (clarifies abuse of discretion in postjudgment relief)
State v. Powell, 126 Wn.2d 244 (Wash. 1995) (untenable grounds defined for discretionary rulings)
In re Marriage of Littlefield, 133 Wn.2d 39 (Wash. 1997) (standard for untenable grounds in discretionary decisions)
State v. Robinson, 172 Wn.2d 783 (Wash. 2011) (postjudgment withdrawal requires CrR 4.2(f) and CrR 7.8 compliance)
State v. A.N.J., 168 Wn.2d 91 (Wash. 2010) (postjudgment withdrawal and manifest injustice analysis)
State v. Taylor, 83 Wn.2d 594 (Wash. 1974) (predecessor guidance on withdrawal standards)
Haner v. State, 95 Wn.2d 858 (Wash. 1981) (limits on amendment discretion under CrR 2.1(d))
Rapozo v. State, 114 Wn. App. 321 (Wash. App. 2002) (trial court may deny amendment irrespective of prejudice)
Puapuaga v. State, 164 Wn.2d 515 (Wash. 2008) (review of dismissal motions for manifest abuse)