Washington State Supreme Court:

State v. Kelly, ___ Wn.2d ___ (No. 102002-3, consolidated with 102003-1): If a Blake vacate does not change the sentencing range, a motion for resentencing is untimely, affirming Richardson; Trial court lacked authority to impose concurrent firearm enhancements at the resentencing.

State v. Vasquez, ___ Wn.2d ___ (No. 102045-7) (Dec. 19, 2024): Resentencing is performed de novo unless the case is remanded by the Appellate Court on restricted issues.

Washington Court of Appeals

In re Parental Rights to A.G.L., A.S.L, and L.E.L., ___ Wn.App.2d ___, No. 86090-9, Div. I, (filed on Oct. 14, 2024, published Dec. 17, 2024): Family Defense: A party moving to vacate under CR 60(b) must establish prima facie evidence of a defense to termination and that their failure to timely appear and answer the petition was due to inadvertence, surprise, mistake, or excusable neglect. Parent did not make that showing.

State v. Haas, ___ Wn.App.2d ___, No. 39752-1, Div. III (Dec. 26, 2024): Exceptional Sentence Up/Major VUCSA: if the State charges each crime individually rather than aggregating them, it cannot apply the VUCSA multiple transactions aggravator to those charges.

State v. Leer, ___ Wn.App.2d ___, No. 86863-2, Div. I (Dec. 30, 2024): VEHICULAR HOMICIDE/ADMISSIBILITY OF BLOOD TEST: The requirements for the admission of blood test evidence are confined to the plain language of RCW 46.61.506(3) and WAC 448-14-020(3). The test of blood stored in an expired vial was admissible.