State of Washington v. Claude L. Merritt

CourtCourt of Appeals of Washington
DecidedJune 11, 2026
Docket40921-0
StatusUnpublished

This text of State of Washington v. Claude L. Merritt (State of Washington v. Claude L. Merritt) 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. Claude L. Merritt, (Wash. Ct. App. 2026).

Opinion

FILED JUNE 11, 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STATE OF WASHINGTON, ) No. 40921-0-III ) Respondent, ) ) v. ) UNPUBLISHED OPINION ) CLAUDE L. MERRITT, ) ) Appellant. )

LAWRENCE-BERREY, J. — Claude Merritt appeals his offender score calculation

and sentencing for the second time. He argues the trial court improperly found that two

out-of-state convictions were comparable to Washington offenses. The State concedes

that one California conviction is not comparable to a Washington offense but argues we

should affirm the trial court’s offender score by examining a different California

conviction. We grant the State’s request to address the different California conviction.

Of the three out-of-state convictions that we are asked to examine, we conclude

that only the different California conviction is comparable to a Washington offense. We

remand again for resentencing. No. 40921-0-III State v. Merritt

FACTS

A jury convicted Claude Merritt of first degree murder and other lesser offenses.

During sentencing, the trial court concluded that Merritt’s prior California conviction for

taking a vehicle without the owner’s consent was comparable to a Washington offense,

bringing his offender score to 1. The trial court sentenced him to 333 months, the top of

the standard range.

First appeal

Merritt sought review, and we affirmed the felony murder conviction and vacated

the other convictions. State v. Merritt, No. 38763-1-III, slip op. at 36 (Wash. Ct. App.

Nov. 28, 2023) (unpublished), https://www.courts.wa.gov/opinions/pdf/387631_unp.pdf.

We also held that the California offense was not legally comparable to Washington’s

taking a motor vehicle without permission because Washington statutes define “motor

vehicle” more narrowly than the California statutes define “vehicle.” Id. at 16. We noted

the record was insufficient to determine if the California offense was factually

comparable because the State provided only a certified docket showing the conviction

and Merritt’s no-contest plea. Id. at 17. As a result, we remanded the case and directed

the court to conduct a factual comparability analysis. Id. We noted that “the parties must

2 No. 40921-0-III State v. Merritt

be given the opportunity to present all relevant evidence of criminal history, including

criminal history not previously presented.” Id. at 17-18 (citing RCW 9.94A.530(2)).

On remand, the State introduced the California complaint and the associated

affidavit of probable cause to support its argument that the conviction was factually

comparable to a Washington offense. The information alleged that Merritt did “willfully

and unlawfully drive or take a certain vehicle, . . . without the consent of and with intent

to deprive the said owner of title to or possession of said vehicle.” Clerk’s Papers (CP) at

245 (capitalization omitted). The affidavit of probable cause asserted that Merritt was

seen driving the vehicle, a records check revealed the vehicle was reported stolen, and

there was a shaved key in the ignition.

The State also argued that two other out-of-state convictions should be included in

Merritt’s offender score. One was a California conviction for buying or receiving a

stolen vehicle under California Penal Code § 496d(a), which the State contended was

factually comparable to Washington’s possession of a stolen vehicle. To support its

argument, the State submitted the complaint, the associated affidavit of probable cause,

and evidence that Merritt entered a no-contest plea to the charge. The complaint alleged

that Merritt did “willfully and unlawfully buy or receive a motor vehicle, . . . which had

been stolen or obtained in any manner constituting theft or extortion, knowing that

3 No. 40921-0-III State v. Merritt

property to be stolen or obtained, or who conceals, sells, withholds, or aids in concealing,

selling or withholding said vehicle, knowing the property to be stolen.” CP at 261-62.

The affidavit report asserted that Merritt was found in a stolen “vehicle.” CP at 263.

The State introduced a second new out-of-state conviction, an Illinois conviction

for burglary under 720 Ill. Comp. Stat. 5/19-1(a). The State argued that this conviction

was legally comparable to Washington’s second degree burglary statute. The State

introduced the charging information, the probable cause arrest report, and evidence that

Merritt pleaded guilty to the offense. The information alleged that Merritt “knowingly

and without authority entered a building of Danville Gardens, . . . with the intent to

commit therein a theft.” CP at 277. The probable cause arrest report asserted that three

suspects, including Merritt, were caught on the business’s surveillance video when they

entered through the business’s door by cutting the polycarbonate panel on the door and

unlocking the door. The suspects took a gas can with gas in it, a laptop, and a keyboard.

Merritt’s defense counsel, who did not represent Merritt at the original sentencing

hearing, submitted a sentencing memorandum on remand. When Merritt’s counsel

considered if the California conviction for taking a vehicle without the owner’s consent

was factually comparable with Washington’s taking a motor vehicle without permission,

counsel believed that the affidavit of probable cause proved the offenses were factually

4 No. 40921-0-III State v. Merritt

comparable. However, Merritt’s counsel argued that the California conviction for buying

or receiving a stolen vehicle was not legally or factually comparable. Lastly, Merritt’s

counsel argued that the Illinois burglary conviction was not legally comparable but

conceded that if the court considered the factual question, the State had proved the two

were factually comparable based on the affidavit. Defense counsel conceded that

Merritt’s offender score was 2.

Resentencing hearing

At the resentencing hearing, the trial court referenced our instruction in Merritt

to conduct a factual comparability analysis and noted:

[W]e were directed by Division III to take a look at the actual probable cause affidavit. The State has since acquired those and it does believe—and it does look like reading from the probable cause affidavit that Mr. Merritt was, in fact, in possession of a motor vehicle or a car, which would make it comparable to a Washington taking a motor vehicle second. And as far as the Illinois burglary charge, while there are some statutory differences as far as the . . . predicate crime that needed to be committed[,] . . . if you look at either just the comparable legal standard, or more importantly, the factual standard, it does appear that is factually, and potentially legally comparable, most importantly, to a Washington burg II. So that’ll count.

Rep. of Proc. (Dec. 13, 2024) (RP) at 22.

After the trial court heard argument about the comparability of the California

buying or receiving a stolen vehicle conviction, the court determined that it was not

5 No. 40921-0-III State v. Merritt

legally or factually comparable. The court determined the two were not factually

comparable because the State relied on the affidavit of probable cause to prove factual

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State of Washington v. Claude L. Merritt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-claude-l-merritt-washctapp-2026.