State of Washington v. Jennifer L. Wemhoff

CourtCourt of Appeals of Washington
DecidedNovember 3, 2022
Docket38371-7
StatusPublished

This text of State of Washington v. Jennifer L. Wemhoff (State of Washington v. Jennifer L. Wemhoff) 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. Jennifer L. Wemhoff, (Wash. Ct. App. 2022).

Opinion

NOTICE: SLIP OPINION (not the court’s final written decision)

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FILED NOVEMBER 3, 2022 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. 38371-7-111 ) Respondent, ) ) V. ) PUBLISHED OPINION ) JENNIFERL. WEMHOFF, ) ) Appellant. )

LAWRENCE-BERREY, A.C.J. -The legislature recently amended RCW 9.94A.703.

The amendment removes the condition, waivable by the trial court at sentencing,

requiring defendants to pay community custody supervision fees.

The question on appeal is whether this amendment, effective after sentencing but

before the termination of the appeal, applies here. Because amendments to statutes

imposing costs on criminal defendants apply to cases on appeal, we conclude the

amendment applies here. We remand for the trial court to strike its imposition of the

community custody supervision fees and for correction of a scrivener's error. For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

No. 38371-7-III State v. Wemhoff

FACTS

Jennifer Wemhoff pleaded guilty to two counts of identity theft in the first degree

and three counts of theft in the first degree. On July 26, 2021, the trial court sentenced

her to an exceptional sentence of 48 months of confinement, followed by 12 months of

community custody. The court did not discuss or alter the standard provision in the

judgment and sentence that required payment of supervision fees for community custody.

In addition, Ms. Wemhoff’s judgment and sentence included a prior misdemeanor

conviction for frequenting a drug house. The date listed for that crime was December 6,

2011, and the date listed for sentencing was February 21, 2021. Apparently, the last two

numbers in the year were transposed. Ms. Wemhoff timely appealed.

ANALYSIS

Ms. Wemhoff argues the trial court erred when it imposed community custody

supervision fees and her sentence contains a scrivener’s error. We address each argument

in turn.

A. COMMUNITY CUSTODY SUPERVISION FEES

RCW 9.94A.703 sets forth which community custody conditions a trial court must

impose and which it may waive. Until recently, former RCW 9.94A.703(2)(d) (2018)

provided: “Unless waived by the court, as part of any term of community custody, the

2 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

court shall order an offender to . . . [p]ay supervision fees as determined by the

[Department of Corrections].” Earlier this year, the legislature amended the statute. See

SECOND SUBSTITUTE H.B. 1818, 67th Leg., Reg. Sess. (Wash. 2022). The amendment

has an effective date of July 1, 2022, and deletes the subsection from the statute. We first

must determine whether the former statute or the amended statute applies.

The State contends RCW 9.94A.345 controls the disposition of this question. The

statute provides: “[A]ny sentence imposed under this chapter shall be determined in

accordance with the law in effect when the current offense was committed.” This statute,

however, has never been extended to costs imposed on a criminal defendant.

In State v. Blank, 131 Wn.2d 230, 233-34, 930 P.2d 1213 (1997), two indigent

defendants challenged the constitutionality of RCW 10.73.160, which permits appellate

courts to impose appellate costs on adult offenders. That statute was enacted while their

appeals were pending. Id. at 234. In addition to other constitutional arguments, the

defendants asserted that retroactive application of the statute to them violated their equal

protection and due process rights. Id. at 249. In refuting this argument, the Blank court

explained why application of the statute to them was prospective, not retroactive:

3 For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.

[A] statute does not operate retroactively “merely because it relates to prior facts or transactions where it does not change their legal effect. It is not retroactive because some of the requisites for its actions are drawn from a time antecedent to its passage . . . .” State v. Scheffel, 82 Wn.2d 872, 879, 514 P.2d 1052 (1973). “A statute operates prospectively when the precipitating event for [its] application . . . occurs after the effective date of the statute . . . .” Aetna Life Ins. Co. v. Wash. Life & Disability Ins. Guar. Ass’n, 83 Wn.2d 523, 535, 520 P.2d 162 (1974).

Id. at 248 (alterations in original). The Blank court held, “The precipitating event for

application of a statute concerning attorney fees and costs of litigation is termination of

the case.” Id. at 249.

In State v. Ramirez, 191 Wn.2d 732, 748, 426 P.3d 714 (2018), the court

considered an amendment to RCW 10.01.160, which prohibits trial courts from imposing

discretionary costs on defendants who are indigent at the time of sentencing. There, the

court noted in Blank, “we held that a statute imposing appellate costs applied

prospectively to the defendants’ cases on appeal.” Id.

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Related

State v. Scheffel
514 P.2d 1052 (Washington Supreme Court, 1973)
State v. Blank
930 P.2d 1213 (Washington Supreme Court, 1997)
State v. Davis
248 P.3d 121 (Court of Appeals of Washington, 2011)
State v. Ramirez
426 P.3d 714 (Washington Supreme Court, 2018)
State v. Blank
131 Wash. 2d 230 (Washington Supreme Court, 1997)
State v. Hayes
182 Wash. 2d 556 (Washington Supreme Court, 2015)
State v. Davis
160 Wash. App. 471 (Court of Appeals of Washington, 2011)
State v. Hayes
312 P.3d 784 (Court of Appeals of Washington, 2013)
State v. Jenks
Washington Supreme Court, 2021

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