prior-conviction exception (Washington) · Go Syfert
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prior-conviction exception in Washington

7 Washington opinions name it 1 courts 2006–2015 0 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
United States v. Mooregreen
ca10 · 2005 · cited in 3 Washington opinions naming this issue, 2007–2010
2 sentences

2010In State v. Jones, 159 Wash.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 , 127 S.Ct. 2066 , 167 L.Ed.2d 790 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context stating, *274 To give effect to the prior conviction exception, Washington's sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts "intimately related to [the] prior conviction" such as the defendant's community custody status. 159 Wash.2d at 241,

2010In State v. Jones, 159 Wn.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context, stating, To give effect to the prior conviction exception, Washington’s sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts “intimately related to [the] prior conviction” such as the defendant’s community custody status. 159 Wn.2d at 241 (alteration in original) (quoting United Sta

33
State v. Jonesgreen
wash · 2006 · cited in 4 Washington opinions naming this issue, 2007–2010
2 sentences

2010In State v. Jones, 159 Wash.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 , 127 S.Ct. 2066 , 167 L.Ed.2d 790 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context stating, *274 To give effect to the prior conviction exception, Washington's sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts "intimately related to [the] prior conviction" such as the defendant's community custody status. 159 Wash.2d at 241,

2010In State v. Jones, 159 Wn.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context, stating, To give effect to the prior conviction exception, Washington’s sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts “intimately related to [the] prior conviction” such as the defendant’s community custody status. 159 Wn.2d at 241 (alteration in original) (quoting United Sta

14
State Oil Co. v. Khanred
· 1997 · cited in 1 Washington opinions naming this issue, 2007–2007
2 sentences

2007See, e.g., id. at 239 n.7 (“Even if we were inclined to agree with the dissent’s unstated assertion that it is only a matter of time before that case is overruled, we are certainly not free to overrule or ignore established Supreme Court precedent.” “ ‘[I]t is [the Supreme] Court’s prerogative alone to overrule one of its precedents.’ ” (second alteration in original) (quoting State Oil Co. v. Khan, 522 U.S. 3, 20 , 118 S. Ct. 275 , 139 L.

2007See, e.g., id. at 239 n.7 (“Even if we were inclined to agree with the dissent’s unstated assertion that it is only a matter of time before that case is overruled, we are certainly not free to overrule or ignore established Supreme Court precedent.” “ ‘[I]t is [the Supreme] Court’s prerogative alone to overrule one of its precedents.’ ” (second alteration in original) (quoting State Oil Co. v. Khan, 522 U.S. 3, 20 , 118 S. Ct. 275 , 139 L.

11
State v. Ortegagreen
washctapp · 2004 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., State v. Ortega, 120 Wash. App. 165 , 84 P.3d 935 (2004). . . . .

11
State v. Ortegagreen
washctapp · 2004 · cited in 1 Washington opinions naming this issue, 2007–2007
1 sentence

2007See, e.g., State v. Ortega, 120 Wash. App. 165 , 84 P.3d 935 (2004). . . . .

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
State v. Jones green
wash · 2006
2 sentences

2010In State v. Jones, 159 Wash.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 , 127 S.Ct. 2066 , 167 L.Ed.2d 790 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context stating, *274 To give effect to the prior conviction exception, Washington's sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts "intimately related to [the] prior conviction" such as the defendant's community custody status. 159 Wash.2d at 241,

2010In State v. Jones, 159 Wn.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context, stating, To give effect to the prior conviction exception, Washington’s sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts “intimately related to [the] prior conviction” such as the defendant’s community custody status. 159 Wn.2d at 241 (alteration in original) (quoting United Sta

42007–2010
Almendarez-Torres v. United States red
scotus · 1998
2 sentences

2015The Apprendi Court based the prior- conviction exception to its general rule on Almendarez -Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L.

2015The Apprendi Court based the prior- conviction exception to its general rule on Almendarez -Torres v. United States, 523 U.S. 224 , 118 S. Ct. 1219 , 140 L.

32007–2015
Thomas v. Washington green
scotus · 2007
2 sentences

2010In State v. Jones, 159 Wash.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 , 127 S.Ct. 2066 , 167 L.Ed.2d 790 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context stating, *274 To give effect to the prior conviction exception, Washington's sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts "intimately related to [the] prior conviction" such as the defendant's community custody status. 159 Wash.2d at 241,

2010In State v. Jones, 159 Wn.2d 231 , 149 P.3d 636 (2006), cert. denied, 549 U.S. 1354 (2007), our Supreme Court defined the scope of the prior-conviction exception to the Blakely/Apprendi jury trial requirement in the community custody context, stating, To give effect to the prior conviction exception, Washington’s sentencing courts must be allowed as a matter of law to determine not only the fact of a prior conviction but also those facts “intimately related to [the] prior conviction” such as the defendant’s community custody status. 159 Wn.2d at 241 (alteration in original) (quoting United Sta

22010–2010
Old Chief v. United States green
scotus · 1997
2 sentences

2006Ortega's stipulation would have eliminated the statutory language that he agreed was an element: that his convictions were for violating protection orders. ¶ 17 The statute construed in Old Chief made it a crime for a felon to be in possession of a firearm but did not require a specific kind of felony: The statutory language in which the prior-conviction requirement is couched shows no congressional concern with the specific name or nature of the prior offense beyond what is necessary to place it within the broad category of qualifying felonies, and Old Chief clearly meant to admit that his fe

2006Ortega’s stipulation would have eliminated the statutory language that he agreed was an element: that his convictions were for violating protection orders. ¶17 The statute construed in Old Chief made it a crime for a felon to be in possession of a firearm but did not require a specific kind of felony: The statutory language in which the prior-conviction requirement is couched shows no congressional concern with the specific name or nature of the prior offense beyond what is necessary to place it within the broad category of qualifying felonies, and Old Chief clearly meant to admit that his fel

22006–2006
State v. Ball green
washctapp · 2005
1 sentence

2007Ball, 127 Wash.App. at 957 n. 1, 113 P.3d 520 . [14] State v. Jones, 159 Wash.2d 231, 241 , 149 P.3d 636 (2006). [15] The Jones Court addressed and concluded that under the prior-conviction exception, the sentencing court could determine, as a "matter of law," whether a defendant was on community custody at the time he committed the current offense because this fact was closely related to and flowed directly from the fact of the prior conviction.

12007–2007
State v. Ball green
washctapp · 2005
1 sentence

2007Ball, 127 Wash.App. at 957 n. 1, 113 P.3d 520 . [14] State v. Jones, 159 Wash.2d 231, 241 , 149 P.3d 636 (2006). [15] The Jones Court addressed and concluded that under the prior-conviction exception, the sentencing court could determine, as a "matter of law," whether a defendant was on community custody at the time he committed the current offense because this fact was closely related to and flowed directly from the fact of the prior conviction.

12007–2007

Statutes the citing opinions construe

WA § Wash. Rev. Code § 9.41.010 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

MN 10 (2009–2024) IL 10 (1984–2025) WA 7 (2006–2015) CO 7 (2005–2015) OH 5 (1999–2016) AZ 2 (1989–1990) KS 2 (2010–2026) OR 2 (2007–2021)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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