State Of Washington, V. Joseph Lewis Jones

CourtCourt of Appeals of Washington
DecidedMarch 2, 2026
Docket87163-3
StatusUnpublished

This text of State Of Washington, V. Joseph Lewis Jones (State Of Washington, V. Joseph Lewis Jones) 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. Joseph Lewis Jones, (Wash. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 87163-3-I Respondent, DIVISION ONE v. UNPUBLISHED OPINION JOSEPH LEWIS JONES,

Appellant.

DÍAZ, J. — Our Supreme Court granted Joseph Lewis Jones’s Personal

Restraint Petition (PRP) in part after the State conceded the facial invalidity of two

conditions. At the subsequent hearing, the trial court adopted the State’s proposed

revisions to those conditions, over Jones’s objections. Jones now argues, in

pertinent part, that the conditions are unconstitutional because they are not

narrowly tailored. We agree and remand for the trial court to reconsider the

conditions consistent with the guidance in this opinion.

I. BACKGROUND

In 2010, a jury convicted Jones of rape of a child in the first degree. The

court sentenced Jones to 100 months’ confinement and community custody upon

Jones’s release from prison, with various conditions. Jones appealed his

conviction, which this court affirmed. He subsequently filed two PRPs, which this No. 87163-3-I/2

court dismissed in 2014 and 2016. In 2019, Jones was released from prison.

In July 2022, Jones filed another PRP, this time arguing inter alia that some

of his conditions of community custody were facially invalid. The State conceded

that conditions 13, 15, 22, and 23 were facially invalid, and proposed revisions for

each condition. Our Supreme Court granted the PRP in part based on the State’s

concessions and remanded the matter to the trial court to “make necessary

corrections.”

The trial court adopted the revisions that the State proposed. Specifically,

conditions 22 and 23 were modified as follows (where strike-through text

represents deletions and underlined text are additions):

22. Do not purchase, possess, or use consume alcohol (beverage or medicinal), and submit to testing and reasonable searches of your person, residence, property and vehicle by the Community Corrections Officer [(CCO)] to monitor compliance.

23. Do not use or access the Internet World Wide Web, including email, without the prior approval of your except as specifically authorized by the supervising [CCO] and sex offender treatment provider through approved filters. The CCO is permitted to monitor the filters for compliance with this condition.

Jones now challenges the constitutionality of the revised conditions 22 and 23. 1

1 In his pro se statement of additional grounds (SAG), Jones challenges the same

conditions challenged in his Appellant’s brief. Arguments adequately addressed in an opening brief are not proper for an SAG. See RAP 10.10(a); State v. Jackson, 129 Wn. App. 95, 98 n. 6, 117 P.3d 1182 (2005). He also challenges a “business frequency rule” and “travel restrictions” but does not clarify which additional community custody conditions he is referring to. We are not required to address a claim that is “too vague to allow us to identify the issue.” State v. Bluehorse, 159 Wn. App. 410, 436, 248 P.3d 537 (2011). To the extent that Jones cites authority supporting his claims, he does not explain how the authority supports his arguments. “It is not the responsibility of this court to attempt to discern what it is appellant may have intended to assert that might somehow have merit.” Port Susan Chapel of the Woods v. Port Susan Camping Club, 50 Wn. 2 No. 87163-3-I/3

II. ANALYSIS

As a preliminary matter, the State asserts that Jones’s challenge would

have required the trial court to exceed the scope of the mandate from our Supreme

Court. The State claims that our Supreme Court’s mandate required the trial court

to mechanically correct the conditions to match the revisions the State proposed.

We disagree.

Our Supreme Court remanded for the trial court to make necessary

corrections “based on the State’s concession,” meaning the remand was

necessary because the State conceded facial invalidity. Nothing in the order

indicates that our Supreme Court “found that the State’s proposed language . . .

adequately mended any constitutional invalidity.”

Our Supreme Court did not “clearly convey the intent to limit the scope” of

review, and so the trial court had the discretion to consider whether the conditions

violated Jones’s constitutional rights. State v. Dunbar, 27 Wn. App. 2d 238, 246,

532 P.3d 652 (2023) (citing State v. Hardy, 250 N.C. App. 225, 792, S.E.2d 564,

569 (2012)).

That said, the State is correct that, pursuant to RCW 10.73.100, the

argument that the conditions are not crime-related is time-barred, if not also

waived. We therefore exercise our discretion under RAP 2.5 to review only

whether each condition is valid on its face. In re the Pers. Restraint of Williams,

200 Wn.2d 622, 632, 520 P.3d 933 (2022). 2 Jones argues that both conditions

App. 176, 188, 746 P.2d 816 (1987). We therefore do not address the arguments raised in the SAG. 2 More specifically, the State claims that Jones’s arguments are waived because

3 No. 87163-3-I/4

violate his constitutional rights. We review constitutional questions de novo. State

v. Wallmuller, 194 Wn.2d 234, 238, 449 P.3d 619 (2019).

A. Condition 22

Jones argues that condition 22—which states, “Do not consume alcohol

(beverage or medicinal), and submit to testing and reasonable searches of your

person, residence, property and vehicle by the [CCO] to monitor compliance”—

violates his right to privacy and is not narrowly tailored. We remand so that the

trial court may clarify the scope of the “reasonable searches.”

Our state constitution provides that “[n]o person shall be disturbed in his

private affairs, or his home invaded, without authority of law.” WASH. CONST. art. I,

§ 7. It is well established that probationers have a more reduced expectation of

privacy than ordinary citizens because they are “persons whom a court has

sentenced to confinement, but who are serving their time outside the prison walls.”

State v. Olsen, 189 Wn.2d 118, 124-25, 399 P.3d 1141 (2017). But probationers

still retain their constitutional rights and “thus some authority of law must still justify

the intrusion into their reduced expectation of privacy.” Id. at 126. A balancing

test—whether a compelling interest, achieved through narrowly tailored means,

supports the intrusion into a probationer’s reduced privacy interests—is

appropriate to evaluate the constitutionality of the conditions. Id. at 127-28.

he did not raise these challenges before the trial court. Jones challenged the constitutionality of condition 23 both in his memorandum to the trial court, CP 51- 52, and at the hearing before the trial court, RP 9-11. In his brief, he argues that condition 22 is unconstitutional “[o]n its face” and therefore a manifest constitutional error. We therefore exercise our discretion under RAP 2.5(a) to consider both constitutional claims, which the State does not challenge on the merits. 4 No. 87163-3-I/5

The State has a compelling interest in monitoring compliance with valid

community custody conditions. State v.

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Related

State v. Bahl
193 P.3d 678 (Washington Supreme Court, 2008)
State v. Bluehorse
248 P.3d 537 (Court of Appeals of Washington, 2011)
State v. Hardy
792 S.E.2d 564 (Court of Appeals of North Carolina, 2016)
Packingham v. North Carolina
582 U.S. 98 (Supreme Court, 2017)
State v. Cornwell
412 P.3d 1265 (Washington Supreme Court, 2018)
State v. Wallmuller
449 P.3d 619 (Washington Supreme Court, 2019)
State v. Bahl
164 Wash. 2d 739 (Washington Supreme Court, 2008)
State v. Jackson
117 P.3d 1182 (Court of Appeals of Washington, 2005)
State v. Bluehorse
159 Wash. App. 410 (Court of Appeals of Washington, 2011)
State v. Padilla
416 P.3d 712 (Washington Supreme Court, 2018)
Port Susan Chapel v. Port Susan Camping Club
746 P.2d 816 (Court of Appeals of Washington, 1987)
State v. Johnson
Washington Supreme Court, 2021
State of Washington v. Daniel Herbert Dunbar
Court of Appeals of Washington, 2023

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