State v. Medina
180 Wash. 2d 282
| Wash. | 2014Background
- Medina, awaiting retrial on second-degree murder charges, was ordered into CCAP Enhanced and CCAP Basic and participated for about five years before his retrial resulted in a conviction.
- Initial 1998 charges: first-degree murder, jury convicted second-degree felony murder based on a predicate second-degree assault; convictions later vacated by Andress decision.
- Remand and retrial: on remand (2005) Medina faced first-degree manslaughter charges; retrial proceeded after appellate review; during pendency, he remained on pretrial release subject to CCAP.
- CCAP structure: two tracks (Enhanced and Basic); Enhanced required in-person daily reporting; Basic required only telephone reporting; Medina’s participation spanned 2007–2011 with roughly nine months in Enhanced and about three years and nine months in Basic.
- Statutory framework: SRA provisions govern pretrial credit; 1997 and later amendments address credit for time served in CCAP; question is whether CCAP time constitutes “partial confinement” and whether credit is mandatory or discretionary; court concludes CCAP time is not “confinement” and credit is not mandatory for Medina.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the SRA allows credit for pretrial CCAP time | Medina seeks credit under pretrial confinement rules. | CCAP time is not confinement under the SRA. | No credit for CCAP time; CCAP not partial confinement under the 1997 law. |
| Effect of the 2009 amendments on Medina’s eligibility | Amendment expansion shows intent to credit CCAP time. | Amendment applies only to nonviolent offenses. | Amendment scope is limited; Medina’s eligibility governed by 1997 SRA law, not the 2009 changes. |
| Double jeopardy and equal protection challenges | Failure to credit CCAP time violates equal protection and double jeopardy. | Credit distinctions for time served are rational and permissible. | No equal protection or double jeopardy violation; rational basis supports denial. |
Key Cases Cited
- Speaks v. State, 119 Wn.2d 204 (1992) (presentence EHD credit despite postconviction confinement rules)
- Reanier v. Smith, 83 Wn.2d 342 (1974) (credit for pretrial time; equal protection considerations)
- Harris v. Charles, 171 Wn.2d 455 (2011) (credit for EHD pretrial time permissible for nonuniform categories; rational distinctions allowed)
- In re Personal Restraint of Andress, 147 Wn.2d 602 (2002) (construction of predicate offenses; remediation of predicate failure)
- Wash. Nat. Gas Co. v. P.U.D. No. 1 of Snohomish County, 77 Wn.2d 94 (1969) (statutory designation implies omission of other things)