Resources

Brief Bank

Brief Bank Information

WDA has created a brief bank for use by its members and those engaged in indigent defense in Washington State. This bank was created by the resource attorneys, who have either written these motions or received them from other practicing attorneys. If you have a motion that you would like to contribute to this bank, please contact the resource attorneys, who will then update and publish it to the bank.

AOC Brief Bank

The Administrative Office of the Courts (AOC) maintains a brief bank that is based upon the briefs filed for indigent appeals in the Washington State Courts of Appeal and Washington State Supreme Court in the last ten or more years. Follow this link to their website.

Strengthening the Sixth Amendment

Below are resources from the Strengthening the Sixth Amendment organization presentation on jury diversity webinar series. The recording and other resources available at https://strengthenthesixth.org/. The resources include:

 

As with all resources, WDA staff does its best to keep the brief bank updated but it is your obligation to make sure that the caselaw is still current.

 

Below are the most recently updated documents and links in all brief bank subcategories.

Late Appeal – Mtn to Extend Time to File (2021)

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Good Time on Mand Min Portion for 1998 Crime (2.2024)

This brief argues that the defendant can earn good time on the mandatory minimum portion of a sentence for a 1998 offense. Thanks to Scott McGinty for sharing this brief.

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Expired Vials Rulings Compiled by Dustin Howie (Link)

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Spokane Superior Court RALJ Decision on Delay and Expired Vials in Blood Test DUI

The ruling includes some strong language regarding expired vials: “The Court finds that prejudice exists and concurs with Spokane Municipal Court that prejudice results from a DUI blood test with an expired tube on these facts....

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Spokane Superior Court RALJ Decision on Preaccusatorial Delay in Blood Test DUI

The ruling includes some strong language regarding expired vials: “The Court finds that prejudice exists and concurs with Spokane Municipal Court that prejudice results from a DUI blood test with an expired tube on these facts....

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Jefferson County Ruling Suppressing Blood Test Result Due to Expired Vial

This ruling from Jefferson County District Court orders suppression due to expired vial testing.  There is language in the Court’s ruling that Dr. Couper was “not able to answer questions relating to expired vials” and “c...

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Motion & Order for Witness Deposition Per CrR 4.6(a)

Motion provides the alternative to attend deposition via Zoom or in person with digital recorder rather than court reporter. [Remember that the advantages to obtaining a deposition are sworn testimony and the court reporter’...

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Defense Discovery Deposition Motion

Combined order to compel the State to provide contact information for law enforcement and civilian witnesses, and to be allowed to audio tape or video tape record the interview in lieu of having a court reporter handle the deposit...

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2024_Refrigerator Outages Arguments by Dustin Howie

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Motion for Late Appeal with Reply (11.2022)

This Motion and Reply argue the appellate received affirmative misadvice from the court regarding the right to appeal, thus no waiver of right to appeal in a late filing of direct appeal. Thanks to Jeff Ellis for this briefing.

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