Revised Code of Washington

Wash. Rev. Code § 13.40.180 (2026)

✓ current as of May 2026
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(1) Where a disposition in a single disposition order is imposed on a youth for two or more offenses, the terms shall run consecutively, subject to the following limitations:
(a) Where the offenses were committed through a single act or omission, omission, or through an act or omission which in itself constituted one of the offenses and also was an element of the other, the aggregate of all the terms shall not exceed 150 percent of the term imposed for the most serious offense;
(b) The aggregate of all consecutive terms shall not exceed three hundred percent of the term imposed for the most serious offense; and
(c) The aggregate of all consecutive terms of community supervision shall not exceed two years in length, or require any payment of fines or the performance of more than 200 hours of community restitution.
(2) Where disposition in separate disposition orders is imposed on a youth, the periods of community supervision contained in separate orders, if any, shall run concurrently. All other terms contained in separate disposition orders shall run consecutively.
[ 2023 c 449 s 19; 2012 c 177 s 3; 2002 c 175 s 24; 1981 c 299 s 14; 1977 ex.s. c 291 s 72.]

Notes:

Effective date2023 c 449: See note following RCW 13.40.058.
Effective date2002 c 175: See note following RCW 7.80.130.
Effective datesSeverability1977 ex.s. c 291: See notes following RCW 13.04.005.
Notes of Decisions
Cited in 30 cases (4 in the last 5 years), 1979–2025 · leading case: State v. Contreras, 880 P.2d 1000 (Wash. 1994).
State v. Contreras, 880 P.2d 1000 (Wash. 1994). · cites it 17× “RCW 13.40.180 provides in relevant part: Where a disposition is imposed on a youth for two or more offenses, the terms shall run consecutively, subject to the following limitations: (1) Where the offenses were committed through a single act or omission, omission, or through an…”
State v. Ferreira, 850 P.2d 541 (Wash. Ct. App. 1993). · cites it 8× “For these reasons, we conclude that crimes involving multiple victims must be treated separately for purposes of sentencing under RCW 13.40.180. As the trial court determined, RCW 13.”
State v. SSY, 241 P.3d 781 (Wash. 2010). · cites it 17× “pursuant to RCW 13.40.180. On review S.S.Y. contends the sentence violates double jeopardy protections because there is no evidence the legislature intended to punish first degree robbery and first degree assault separately.”
State v. S.S.Y., 170 Wash. 2d 322 (Wash. 2010). · cites it 17× “pursuant to RCW 13.40.180. On review S.S.Y. contends the sentence violates double jeopardy protections because there is no evidence the legislature intended to punish first degree robbery and first degree assault separately.”
State v. Schaaf, 743 P.2d 240 (Wash. 1987). · cites it 2× “Provision is made for consecutive sentences (RCW 13.40.180) and even community service is intended as punishment (RCW 13.”
State v. Lawley, 591 P.2d 772 (Wash. 1979). · cites it 2× “Provision is made for consecutive sentences (RCW 13.40.180) and even community service is intended as punishment (RCW 13.”
State v. Paine, 850 P.2d 1369 (Wash. Ct. App. 1993). · cites it 2× “2d 547 (1990), defense counsel did not raise the objection at sentencing that the court's sentence violated the 300 percent rule of RCW 13.40.180(2). This, however, was the sole issue argued on appeal.”
State v. SSY, 207 P.3d 1273 (Wash. Ct. App. 2009). · cites it 18× “That statute provides: Where a disposition is imposed on a youth for two or more offenses, the terms shall run consecutively, subject to the following limitations: (1) Where the offenses were committed through a single act or omission, omission, or through an act or omission…”
State v. S.S.Y., 150 Wash. App. 325 (Wash. Ct. App. 2009). · cites it 18× “The legislature, however, expressed its intent to punish these offenses separately under RCW 13.40.180 of the Juvenile Justice Act.”
State v. Robertson, 947 P.2d 765 (Wash. Ct. App. 1997). · cites it 3× “Antimerger Jack argues that the trial court violated RCW 13.40.180(1) by imposing separate sentences for assault and malicious harassment.”
In Re the Pers. Restraint of Smiley, 640 P.2d 7 (Wash. 1982). · cites it 2× “080 (dealing with adult sentences) and RCW 13.40.180 (dealing with juvenile sentences) both require consecutive sentencing for separate offenses, the Department of Juvenile Rehabilitation cannot run Smiley's juvenile sentence concurrent to his adult sentence.”
State v. Anderson, 791 P.2d 547 (Wash. Ct. App. 1990). · cites it 3× “The single issue on appeal is whether Anderson's sentence violates the 300 percent rule of RCW 13.40.180(2). On August 17, 1988, after Anderson entered a plea of guilty, the trial court ordered 32 days of confinement as follows: Taking a Motor Vehicle Without Permission (4…”
— Wash. Rev. Code § 13.40.180(1) — 11 cases
State v. Contreras, 880 P.2d 1000 (Wash. 1994). “RCW 13.40.180 provides in relevant part: Where a disposition is imposed on a youth for two or more offenses, the terms shall run consecutively, subject to the following limitations: (1) Where the offenses were committed through a single act or omission, omission, or through an…”
State v. Ferreira, 850 P.2d 541 (Wash. Ct. App. 1993). “For these reasons, we conclude that crimes involving multiple victims must be treated separately for purposes of sentencing under RCW 13.40.180. As the trial court determined, RCW 13.”
State v. SSY, 241 P.3d 781 (Wash. 2010). “pursuant to RCW 13.40.180. On review S.S.Y. contends the sentence violates double jeopardy protections because there is no evidence the legislature intended to punish first degree robbery and first degree assault separately.”
State v. S.S.Y., 170 Wash. 2d 322 (Wash. 2010). “pursuant to RCW 13.40.180. On review S.S.Y. contends the sentence violates double jeopardy protections because there is no evidence the legislature intended to punish first degree robbery and first degree assault separately.”
State v. Robertson, 947 P.2d 765 (Wash. Ct. App. 1997). “Antimerger Jack argues that the trial court violated RCW 13.40.180(1) by imposing separate sentences for assault and malicious harassment.”
— Wash. Rev. Code § 13.40.180(1)(a) — 1 case
State Of Washington, V A.c.m. (Wash. Ct. App. 2013).
— Wash. Rev. Code § 13.40.180(1)(b) — 1 case
State Of Washington, V A.c.m. (Wash. Ct. App. 2013).
— Wash. Rev. Code § 13.40.180(2) — 7 cases
State v. Paine, 850 P.2d 1369 (Wash. Ct. App. 1993). “2d 547 (1990), defense counsel did not raise the objection at sentencing that the court's sentence violated the 300 percent rule of RCW 13.40.180(2). This, however, was the sole issue argued on appeal.”
State v. Anderson, 791 P.2d 547 (Wash. Ct. App. 1990). “The single issue on appeal is whether Anderson's sentence violates the 300 percent rule of RCW 13.40.180(2). On August 17, 1988, after Anderson entered a plea of guilty, the trial court ordered 32 days of confinement as follows: Taking a Motor Vehicle Without Permission (4…”
State v. Chavez, 180 P.3d 1250 (Wash. 2008).
State v. Brown, 737 P.2d 288 (Wash. Ct. App. 1987).
State v. Chavez, 180 P.3d 1250 (Wash. 2008).
— Wash. Rev. Code § 13.40.180(3) — 1 case
In Re the Welfare of Hoffer, 659 P.2d 1124 (Wash. Ct. App. 1983).
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