State v. Williams
181 Wash. 2d 795
| Wash. | 2014Background
- In 2010 Christian Williams was convicted of residential burglary and first-degree trafficking in stolen property after stealing items from a friend and returning most of them.
- At sentencing the State counted four prior adult convictions; two prior convictions from 2004 (robbery and burglary) were counted separately, raising Williams’s offender score.
- Williams argued the 2004 robbery and burglary encompassed the same criminal conduct and therefore should be counted as a single prior offense under the Sentencing Reform Act (SRA), RCW 9.94A.525(5)(a)(i).
- The sentencing court declined to apply the SRA same-criminal-conduct analysis, instead relying on the burglary antimerger statute, RCW 9A.52.050, and counted the priors separately.
- The Court of Appeals held the antimerger statute does not apply to scoring prior convictions and reversed for resentencing; the State appealed to the Supreme Court.
- The Supreme Court affirmed, holding the burglary antimerger statute applies only to prosecution/punishment of current offenses and does not override the SRA requirement to treat prior convictions as one offense when they encompass the same criminal conduct.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the burglary antimerger statute allows sentencing courts to count prior convictions separately despite an SRA same-criminal-conduct finding | Williams: prior robbery and burglary were the same criminal conduct and must be counted as one under RCW 9.94A.525(5)(a)(i) | State: burglary antimerger statute permits separate counting/prosecution and supersedes the SRA for burglary priors (relying on dicta in Lessley) | Held: No. The antimerger statute applies only to prosecution/punishment of current offenses and does not displace the SRA’s requirement that priors that encompass the same criminal conduct be counted as one offense. |
Key Cases Cited
- State v. Lessley, 827 P.2d 996 (Wash. 1992) (discussed antimerger principle for current offenses)
- State v. Aldana Graciano, 295 P.3d 219 (Wash. 2013) (same-criminal-conduct analysis framework cited)
- Rutledge v. United States, 517 U.S. 292 (1996) (recognition that second convictions carry collateral consequences)
- Ball v. United States, 470 U.S. 856 (1985) (discussed collateral consequences of convictions)