Resources

Sentencing (Non-LFO)

Exceptional Sentence FOF COL – Conduct at Low End of Range/de minimus

Judge finds conduct at low end of range in shoplift from Walmart following trespass admonishment. Thanks to Victoria Blumhorst of Spokane County Public Defense

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Exceptional Sentence Down – Conduct at Low End of Range/de minimus

This brief argues for a departure from the standard range in a second degree burglary where the allegation involves shoplift at Walmart of small value items after trespass admonishment issued. Thanks to Victoria Blumhorst of Spoka...

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Exceptional Sentence/Mitigated Revocation POSA- Raciallly Biased Policing

In this memo, defense argues that a sanction for revocation of POSA should be mitigated by the client’s recent history as a domestic violence victim, recent success in accessing supportive services, and as a victim of downto...

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Exceptional Sentence Down-Racially Biased Policing (FOF/COL)(2015)

This is the FOF/COL for a departure downward on a POSA revocation based on (1) past convictions were the product of racially biased policing in downtown Seattle, and (2) client’s history as a victim of domestic violence. Tha...

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Felony Involving Vehicle- No Basis to Revoke License

This brief argues the court can not revoke a driver’s license based on a conviction for possession of a stolen car. Thanks to Chad Dold

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Defendant’s Sentence Recommendation

A blank memorandum you can plug your case details into.

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Score-Comparability:AZ Bruglary and Forgery Not Comparable

This sentencing memorandum argues that two prior Arizona convictions are not comparable and do not count in the offender score- forgery and burglary. Thanks to Edwin Aralica

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Exceptional Sentence Down – Mental Impairment/Multiple Offense Policy

This brief argues the court should depart from the standard range in 9 robbery charges due to mental illness and excessive sentence based on multiple offense policy. The defendant had no prior criminal history but decompensated an...

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SSOSA Sentencing Memorandum

Sample defense sentencing motion for special sex offender sentencing alternative.

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Credit for Time Served- NGRI-for all time spent

This brief argues a person committed pursuant to an NGRI should be entitled CFTS for all time spent in custody pre-trial, not just time spent after a 10.77 eval ordered. The AG representing ESH and WSH generally opposes this view,...

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