Court Filings

The Court of Appeals affirmed the trial court’s sentencing of Zachary Boyce. The court held that the 2023 amendment to RCW 9.94A.525, which generally prevents counting most juvenile felony adjudications in an offender score, does not apply retroactively because the legislature did not clearly express that intent. Under Washington law and the savings clause (RCW 10.01.040) and RCW 9.94A.345, defendants must be sentenced according to the law in effect when the offense was committed unless the legislature expressly provides otherwise. Because no clear retroactivity language appeared in the amendment, Boyce’s juvenile adjudications were properly counted.

The Court of Appeals affirmed Samuel Leon Dugan’s convictions and life-without-parole sentence under Washington’s Persistent Offender Accountability Act (POAA). Dugan had been convicted after a bench trial of first-degree promoting prostitution (with domestic violence findings), unlawful possession of a firearm, third-degree assault, and harassment. The trial court found two prior qualifying convictions and imposed mandatory LWOP. The court rejected Dugan’s challenges that the POAA is cruel or discriminatorily applied, and rejected his Sixth Amendment claim that a jury should have decided the timing of prior convictions, relying on state precedent allowing judicial factfinding of prior convictions.