State of Washington v. Claude L. Merritt

Court of Appeals of Washington·Decided June 11, 2026·No. 40921-0·Unpublished

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v. ) UNPUBLISHED OPINION )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.

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 Nov. 28, 2023) (unpublished), https://www.courts.wa.gov/opinions/pdf/387631_unp.pdf.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

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

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

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

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 comparability that stated only that Merritt was found in a stolen “vehicle.” CP at 263. The court noted that “vehicle” was insufficient to determine Merritt possessed a stolen “motor vehicle” under Washington statutes. RP at 27.

The court found that Merritt’s offender score was 2. Based on his offender score, the court resentenced Merritt to 347 months of confinement, the top of the standard range.

Merritt appeals to this court for the second time.

ANALYSIS

OFFENDER SCORE CALCULATIONS Merritt argues the trial court erred by including the California conviction for unlawfully taking a vehicle and the Illinois burglary conviction in his offender score because neither is comparable to Washington crimes.

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