State of Washington v. Brian D. Lively

CourtCourt of Appeals of Washington
DecidedJune 2, 2026
Docket40523-1
StatusUnpublished

This text of State of Washington v. Brian D. Lively (State of Washington v. Brian D. Lively) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. Brian D. Lively, (Wash. Ct. App. 2026).

Opinion

FILED JUNE 2, 2026 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION THREE

STATE OF WASHINGTON, ) ) No. 40523-1-III Respondent, ) ) v. ) ) BRIAN D. LIVELY, ) UNPUBLISHED OPINION ) Appellant. )

STAAB, C.J. — Brian Lively appeals his convictions for third degree assault and

resisting arrest. He contends the court abused its discretion by improperly granting

multiple continuances. The State argues that Lively invited the error by requesting the

continuances, and his failure to follow court rules precludes reversal. Notwithstanding

the State’s misapplication of invited error doctrine, we conclude Lively’s claimed error is

waived and affirm his convictions.

BACKGROUND

Brian Lively was charged by information on December 18, 2023. He was

appointed an attorney and arraigned on January 8, 2024. Lively was detained in jail

while awaiting trial. No. 40523-1-III State v. Lively

Defense counsel successfully moved the court for five continuances on: January

22, February 5, February 26, March 4, and March 18. The State did not object to any of

the continuances, nor did Lively counter his attorney’s motions.

Defense counsel did not provide a reason necessitating the initial continuance

granted on January 22 and the court did not request one. At each of the four subsequent

motion hearings, defense counsel explained that another continuance was necessary to

either conduct additional witness interviews and/or to review and consider a time-served

plea offer made by the State. The record on appeal includes the court’s oral rulings but

no written orders. During one of its five oral rulings—on March 4—the court stated its

reasons for granting the continuance on the record: “Mr. Lively, your matter is going to

be reset in two weeks to see if there is perhaps [a] resolution—that interviews can be

done to prepare your case for trial.” Rep. of Proc. at 373. The court did not articulate its

reasoning in any of its four other rulings.

On April 15, the parties filed an omnibus application indicating June 14 as the last

day of the time for trial period, and a scheduling order setting trial for June 13 and 14.

Lively filed pro se motions on May 1 and May 28. In his first motion, Lively

requested a hearing to dismiss his charges under CrR 3.3(b)(1) and CrR 3.3(f)(2) for

violation of time for trial rights. In the motion and accompanying declaration, Lively

2 No. 40523-1-III State v. Lively

stated he had been incarcerated for 130 days without a trial date and defense counsel had

continued his case five to six times contrary to his express wishes. Lively’s second

motion echoed the first, noting his 155-day period of incarceration and requesting

dismissal for violation of speedy trial. Lively also moved to substitute counsel and later

moved to disqualify the assigned judge.

The court held a special hearing on June 12 to discuss Lively’s motions. The court

determined there was no basis to remove defense counsel or the judge and trial would

proceed the next day as scheduled. RP at 35. Trial occurred on June 13 and 14 and the

jury found Lively guilty as charged on two of the three counts.

Lively appeals.

ANALYSIS

Lively contends the trial court abused its discretion and violated CrR 3.3 by

granting multiple continuances without Lively’s written consent and without finding

good cause. The State argues that Lively invited error by requesting the continuances

and waived any objection by failing to comply with the procedural rules of CrR 3.3. We

conclude that Lively’s claim of error was waived.

We review “trial court decisions to grant or deny motions for continuances [for]

an abuse of discretion.” State v. Downing, 151 Wn.2d 265, 272, 87 P.3d 1169 (2004). A

court abuses its discretion when its decision is manifestly unreasonable or made on

3 No. 40523-1-III State v. Lively

untenable grounds. Id. A misapplication of the law is an abuse of discretion. State v.

Agustin, 1 Wn. App. 2d 911, 916, 407 P.3d 1155 (2018).

Generally, “[a] defendant who is detained in jail shall be brought to trial within . . .

60 days” after “the date of arraignment.” CrR 3.3(b)(1), (c)(1). Continuances or periods

of delay granted by the court are excluded when computing the time for trial. CrR

3.3(e)(3). A continuance may be granted “[u]pon written agreement of the parties” or

“[o]n motion of the court or a party.” CrR 3.3(f)(1)-(2). “The court must state on the

record or in writing the reasons for the continuance.” CrR 3.3(f)(2). Moving for a

continuance “by or on behalf of any party waives that party’s objection to the requested

delay.” Id.

A party who objects to a trial date set outside the time limits prescribed by CrR 3.3

must move the court within 10 days after notice of the trial setting is given. CrR

3.3(d)(3). “A party who fails, for any reason, to make such a motion shall lose the right

to object that a trial commenced on such a date is not within the time limits prescribed by

this rule.” CrR 3.3(d)(3).

Here, the court granted five continuances, each on the motion of defense counsel.

However, the court stated the reasons for the continuance on the record on only one such

occurrence—March 4. Consequently, the court’s failure to make the necessary record for

the continuances granted on January 22, February 5, February 26, and March 18

4 No. 40523-1-III State v. Lively

constitute an abuse of discretion. However, because each motion was made by defense

counsel on behalf of Lively, he waived any objection to the delay.1 See CrR 3.3(f)(2).

Despite this waiver, Lively filed an objection to the trial date on May 1. Even if

we were to consider Lively’s objection, we conclude that it was untimely. Trial was set

on April 15 for June 13 and 14. Under the rule, Lively was required to file any objection

within 10 days of receiving notice of the trial setting, i.e., by April 25. See CrR 3.3(d)(3).

Lively’s objection on May 1 was untimely. As such, even if June 13 was outside the time

limits prescribed by CrR 3.3, Lively lost the right to object under CrR 3.3(d)(3).

Lively argues his case is like State v. Saunders,2 where the appellant’s speedy trial

rights were violated when the trial court granted three continuances without adequate

basis. This comparison fails because of two key differences. First, the defendant in

Saunders expressly, timely, and repeatedly objected to defense counsel’s motions for

continuance. Id. at 212. That did not happen here. Second, the Saunders court failed to

articulate an adequate basis for continuances sought by the State. Id. at 217-19. And

because the State’s motions were not made on behalf of the defendant, the defendant did

1 Lively suggests that any deviation from CrR 3.3 warrants dismissal of charges with prejudice. However, CrR 3.3(h) provides for dismissal only when the defendant’s CrR 3.3 time for trial is violated. 2 153 Wn. App. 209, 217-20, 220 P.3d 1238 (2009).

5 No. 40523-1-III State v. Lively

not waive an objection to the delay. See CrR 3.3(f)(2). Whereas here, all five motions

for continuance were made by defense counsel on Lively’s behalf.

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Related

State v. Campbell
691 P.2d 929 (Washington Supreme Court, 1984)
State v. Saunders
220 P.3d 1238 (Court of Appeals of Washington, 2009)
State v. Downing
87 P.3d 1169 (Washington Supreme Court, 2004)
State v. Luvene
903 P.2d 960 (Washington Supreme Court, 1995)
State Of Washington v. Katrina R. Loos
473 P.3d 1229 (Court of Appeals of Washington, 2020)
State v. Luvene
127 Wash. 2d 690 (Washington Supreme Court, 1995)
State v. Downing
151 Wash. 2d 265 (Washington Supreme Court, 2004)
State v. Ollivier
312 P.3d 1 (Washington Supreme Court, 2013)

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State of Washington v. Brian D. Lively, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-brian-d-lively-washctapp-2026.