In June 2024, the Unites States Supreme Court decided Erlinger v. United States, 144 S.Ct. 1840 (2024), holding that a criminal defendant has both Fifth and Sixth Amendment rights to have a jury unanimously determine beyond a reasonable doubt whether the person’s past offenses were committed on separate occasions as required for enhanced sentencing penalties under the Armed Career Criminal Acct (ACCA).

In this CLE, presenters Chris Petroni and Colin Patrick, experienced criminal defense appellate attorneys, will discuss the Erlinger decision and the ramifications for Erlinger in Washington State Courts.  Attendees will learn what Washington sentencing provisions must be presented to and found by a jury, and what arguments to raise if the sentencing statute does not provide for a jury to make those findings.

To register, please write to wda@defensenet.org with “verdict” in the subject line.

1.25 Law and Legal credits have been requested from the bar.