Monschke Sample Motion to Vacate Sentence (9.2023)

Early Release and Lifetime Parole Inadequate Remedy for Youth <18 (5.2023)

Extend Monschke to 21 Year Olds (8.2023)

Thanks to Jeff Ellis for the brief, arguing that trial courts must have discretion when sentencing 21 year olds for aggravated murder.

Motion To Dismiss-Right to Counsel, Due Process, Speedy, State Mismanagement

This Motion to Dismiss is related to the attorney shortage crisis; the failure to appoint counsel – specifically to in custody clients, but it can be modified for out of custody clients as well. Because it is comprehensive w...

Offender Score -Changes to Juvenile Scoring Apply (8.2023)

This brief argues changes to scoring of juvenile priors applies retroactively. Thanks to Jeff Ellis.

Resentencing Required by CrR 7.8 even if No Change in Range

This brief argues that CrR 7.8 requires resentencing when offender score changes but range does not. Thanks to Jeff Ellis.

Resentencing_Motion to WD Plea Acceptable Remedy (6.2023)

This appellate brief response in the COA argues that withdrawal of plea is an appropriate remedy to Houston Sconiers error. Thanks to Jeff Ellis.

Late Adolescent Defacto Life Juvie Priors as Aggravator Unconstitutional

This brief challenges a de facto life sentence for a late adolescent where juvenile priors used as aggravating circumstance.

Monschke Case Resentencing Options (6.2023)

This sentencing memo argues trial courts can impose a determinate sentence or a juvenile indeterminate sentence in a Monschke resentencing. Thanks to Jeff Elli.

Felony Murder Late Adolescent Minor Accomplice Unconstitutional (6.2023)

'This brief argues the felony murder and mand penalties are unconstitutional for late adolescent who was a minor accomplice. Thanks to Jeff Ellis.