LFO issue in Washington

2016App. 906, 911 , 301 P.3d 492 (2013), we exercised our discretion and declined to review an unpreserved LFO claim.

2016App. 906, 911 , 301 P.3d 492 (2013), and before our Supreme Court’s remand of that decision in State v. Blazina, 182 Wn.2d 827, 834-35 , 344 P.3d 680 (2015) (affirming Court of Appeals’ exercise of discretion to refuse to address LFO issue raised for the first time on appeal, but exercising its own discretion to reach the issue and remand to trial court for further proceedings). ¶49 Although Cardenas-Flores did not raise the issue of her inability to pay LFOs at sentencing, we elect to exercise our discretion to address the issue for the first time on appeal in light of Cardenas-Flores’s indig

2016Consistent with our holding in State v. Lyle, we decline to reach the LFO issue under RAP 2.5(a). 188 Wn.

2016App. 848, 852 , 355 P.3d 327 (2015).

2022App. 2d 690 , 693, 423 P.3d 290 (2018); see also Blazina, 182 Wn.2d at 835 (exercising discretion to review an unpreserved LFO claim in light of “[n]ational and local cries for reform of broken LFO systems”).

2019Id. at 510-11 .

2019Id. at 510-11 .

2018As to the LFO challenge, we remand to the trial court for application of recent legislative No. 49709-3-II amendments to the LFO statutes, consistent with State v. Ramirez, 191 Wn.2d 732 , 426 P.3d 714 (2018).

2018As to the LFO challenge, we remand to the trial court for application of recent legislative No. 49709-3-II amendments to the LFO statutes, consistent with State v. Ramirez, 191 Wn.2d 732 , 426 P.3d 714 (2018).

2017"An important consideration of this analysis is the dollar amount of discretionary LFOs imposed by the sentencing court." Id. 11 No. 34054-6-III State v. Ash In this case, the majority of these factors weigh in favor of reviewing Ash's unpreserved LFO challenge.

2017The State urges this court to decline to accept review of the unpreserved mandatory LFO challenge and to follow State v. Stoddard, 192 Wn.

2017App. 222 , 366 P.3d 474 (2016).

2016App. 245 , 327 P.3d 699 (2014), review . granted, 183 Wn.2d 1013 (2015),1 would affirm. 1 also note that the majority's rationale for declining to review the DNA issue also is equally applicable to the LFO issue.

2016Lyle, 184 Wn.2d 1040 .

2016However, in light of our Supreme Court’s recent order granting the petition for review in Lyle, 365 P.3d 1263 , and remanding to the trial court on the LFO issue presented there, we elect to exercise our discretion whether to reach challenges to discretionary6 LFO’s when not raised in the trial court.

2016Review granted and case remanded to the superior court at 187 Wn.2d 1009 (2017).

2016APPELLATE COSTS On March 4, 2016, Cardenas-Flores filed a supplemental brief opposing appellate costs in light of State v. Sinclair, 192 Wn.

2016In support of this argument, Mr. Gleim cites Stedman v. Cooper, 172 Wn.

2015SAG ISSUE I: Whether the charging document, alleging that the crime(s) were committed "on or between October 31, 2012 and December 15, 2012, " is unconstitutionally vague "Under the Sixth Amendment to the United States Constitution and article I, section 22 of the Washington Constitution, a charging document must include all essential elements of a crime to inform a defendant of the charges against him and to allow preparation for the defense." State v. Kiliona-Garramone, 166 Wn.