St v. Parker Supp Brief of Appellant

Brief – In re Stacy – Challenge to Bail Jump on PCS Charge (2022)

Thanks to Suzanne Elliott for sharing this briefing in In re Stacey. This was a pro se PRP. The COA withdrew its opinion, and appointed counsel.

Resentencing – Including Subsequent Convictions Violates Due Process (2020)

Thanks to Andrea Burkhart for this brief, arguing that the court violates the defendant's due process by including subsequent convictions in an offender score at resentencing.

Amicus Brief, State v. Asaria Miller (3.2022)

Appointment of Counsel in CrR 7.8(b) Motion- 2022 Amendments to CrR 3.1, 7.8 (2.2022)

Motion to Vacate Possession of Legend Drug (9.2021)

This sample motion argues that the court should vacate a conviction for possession of a legend drug. Thanks to Eric Mapes.

Motion to Vacate Inchoate Offense – St. v. Blake (9.2021)

This sample motion to vacate argues that anticipatory offenses of attempted possession, conspiracy to possess and solicitation to possess should be vacated pursuant to State v. Blake.

Felony Resentencing Pathways (3.2022)

SAMPLE Defense Motion to Vacate and Correct Offender Score- State v. Blake (2021)

Blake Research Memo -Whether State May Move to Vacate over Defense Objection (6.2021)

This research memo discusses the legal analysis if the defense opposes a State Motion to Vacate pursuant to St v. Blake.