Motion to Appt Counsel – Monschke (8.2024)

This Sample Motion and Order supports a request for appointment of counsel in a resentencing case impacted by In re Monschke. 

Motion to Modify Community Custody Conditions (6.2024)

Law Review: When a Prison Sentence Becomes Unconstitutional (2022)

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

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.

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.

Motion to Vacate Sentence Remove Juvenile Points from Score (11.2023)

In this motion to vacate, defendant seeks to remove prior juvenile adjudications from his score in a case that has been final for a long time. Thanks to Jeff Ellis for this sample brief.

Resentencing Required Blake Subsequent Conviction Does Not Matter (11.2023)

Thanks to Jeff Ellis for this sample motion to vacate.

Scoring of Juvenile Points – State’s Stock Brief Generic (8.2023)

This is the State's stock brief arguing the juvenile points bill changing scoring of juvenile priors is not retroactive.

POAA Robb 2 Resentencing Required (10.2023)

This motion for direct review asks the WA Supreme Ct to take the issue: does a person with a robb 2 prior used to determine POAA status get a resentencing hearing, even if they still have 3 strikes? Thanks to Jeff Ellis.