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 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.

Declaration of Indigency Motion to Remit or Waive LFOs Felony (05 2023)


Sample Declaration of Indigency Remit or Waive LFOs (05 2023)


Sample Brief – Early Release for Youth Not Adequate Remedy (5.2023)

This PRP Brief seeks resentencing for youth convicted as adult, argues that early release by the ISRB is not a sufficient remedy. Thanks to Jeff Ellis.


Defendant’s Houston Sconiers Sentencing Memo (11.2020)


GR 42 Public Defense Independence

GR 42 Practice Advisory Qualifications Chart 2023 GR 42 Appointment Template


03.24.2023_Blood Alcohol Test Inadmissible in Municipal Court When City Has Not Adopted WACs for Blood Testing by Dustin Howie

This motion argues that a municipal court may not admit a blood test for alcohol in a DUI case when the municipality has adopted RCWs relevant to DUIs but not WACs relevant to blood alcohol testing because RCW 46.61.506 and case l...


03.24.2023_Declaration in Support of Motion to Suppress Blood Test Due Expired Vial by Dustin Howie


03.24.2023_Updated Motion To Suppress Blood Test Based on Expired Vial and Non-Inert Stopper by Dustin Howie


Toxicology Lab Testing Quality Manual

Testing Quality Manual says the following about refrigeration: Refrigerators should maintain average temperatures between 2 and 8°C. Freezers should maintain average temperatures between-20 and -5°C. Individual extreme temperatu...


Toxicology Lab Operations Manual

Operations Manual says the following about refrigeration: Evidence will be stored under refrigeration in the evidence vault upon receipt. Evidence may be removed from refrigeration for accessioning within the evidence vault, and r...