State of Washington v. Max William Jaynes

CourtCourt of Appeals of Washington
DecidedMarch 31, 2026
Docket60061-7
StatusUnpublished

This text of State of Washington v. Max William Jaynes (State of Washington v. Max William Jaynes) 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. Max William Jaynes, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

March 31, 2026

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

STATE OF WASHINGTON, No. 60061-7-II

Respondent,

v. UNPUBLISHED OPINION MAX WILLIAM JAYNES,

Appellant.

VELJACIC, A.C.J. — In 2007, a jury convicted Max W. Jaynes of several offenses including

possession of a controlled substance while armed with a firearm. In 2021, our Supreme Court held

that the former simple possession statute was unconstitutional. State v. Blake, 197 Wn.2d 170,

481 P.3d 521 (2021). The trial court corrected Jaynes’s judgment and sentence to remove the

possession conviction and corresponding firearm enhancement. The court, however, declined to

vacate his judgment and sentence entirely and to conduct a de novo resentencing hearing because

the corrections would not reduce Jaynes’s total base sentence length. Jaynes appeals arguing that

the court erred in not vacating his judgment and sentence and not conducting a de novo

resentencing hearing. We affirm the trial court’s order correcting Jaynes’s judgment and sentence.

FACTS

In 2003, Jaynes got into an argument with his girlfriend who told him to move out. State

v. Jaynes, noted at 131 Wn. App. 1058, 2006 WL 541334 at *1 (2006). Jaynes spent the following

days partying and heavily using substances. Id. Soon after, witnesses observed Jaynes acting 60061-7-II

oddly at multiple locations—pacing outside a home, requesting change at a market, and appearing

at a recreational vehicle (RV) business, where he seemed incoherent and had dilated pupils and

garbled speech. Id. Jaynes then went to the nearby trailer park and drove off in a vehicle belonging

to Donald McCormick. Id

Jaynes returned to the trailer park where he damaged a car with a chain, pointed a gun at

an individual, and later confronted McCormick. Id. at *1-2. Jaynes pointed a gun at McCormick,

attempted to fire it, and ultimately fired a shot into McCormick’s car, lodging a bullet in the back

seat as McCormick drove away. Id. at *2.

Police responded to a 911 call and found Jaynes near a building. Id. After an officer

ordered Jaynes to drop his weapon, Jaynes fired at the officers, prompting an exchange of gunfire

in which Jaynes was shot. Id. Police recovered stolen firearms, ammunition, and drug

paraphernalia containing methamphetamine residue. Id.

The State charged Jaynes with multiple offenses, including unlawful possession of a

controlled substance while armed with a firearm. Id. Ultimately, the jury found Jaynes guilty of

two counts of assault in the first degree, three counts of assault in the second degree, two counts

of unlawful possession of a firearm in the first degree, possession of a stolen firearm, and unlawful

possession of a controlled substance while armed with a firearm.

Based on an offender score of 15, Jaynes’s standard sentence range for one of the assault

in the first degree convictions was 240-318 months. The standard sentence range for the other

assault in the first degree conviction was 93-123 months. The trial court sentenced Jaynes to 240

months and 93 months respectively for a total base sentence of 333 months. The court ran all other

base sentences concurrently to the assault in the first degree sentences.

2 60061-7-II

The trial court imposed 246 months of firearm enhancements to run consecutively to the

base sentence. This total included an 18-month firearm enhancement for the simple possession

conviction. When combined with the 333-month base sentence for the assault in the first degree

convictions, Jaynes’s total sentence was 579 months.

After our Supreme Court’s decision in Blake, Jaynes filed a CrR 7.8 motion to vacate his

simple possession conviction and for resentencing on all convictions. The State agreed that the

simple possession conviction should be vacated and that the associated firearm enhancement

should be removed but argued that Blake did not impact the base sentence, which was controlled

by the assault in the first degree convictions. The trial court agreed with the State.

The trial court denied Jaynes’s request for a full de novo resentencing hearing on all

convictions. The court concluded that Blake had “no practical difference in the sentence.” Clerk’s

Papers at 136. The court instead entered an order amending Jaynes’s judgment and sentence,

vacating the simple possession conviction, reducing Jaynes’s offender scores by one point, and

removing the related 18-month firearm enhancement.

Jaynes appeals the trial court’s denial of his motion for a de novo resentencing hearing.

ANALYSIS

Jaynes contends that the trial court erred in not granting his requested relief in his CrR 7.8

motion for a de novo resentencing hearing. We disagree.

I. STANDARD OF REVIEW

We review a trial court’s ruling on a CrR 7.8 motion for an abuse of discretion. State v.

Lamb, 175 Wn.2d 121, 127, 285 P.3d 27 (2012). “A trial court abuses its discretion if its decision

rests on untenable factual grounds or was made for untenable legal reasons.” State v. Frohs, 22

Wn. App. 2d 88, 92, 511 P.3d 1288 (2022).

3 60061-7-II

II. CrR 7.8(b)

Under CrR 7.8(b), a superior court may relieve a party from a final judgment. However, a

post-conviction motion generally must be filed within one year of the date that the defendant’s

judgment and sentence becomes final. RCW 10.73.090(1). Jaynes’s judgment and sentence

became final in 2006, the date that this court issued its mandate following his direct appeal. RCW

10.73.090(3)(b). Jaynes filed his CrR 7.8(b) motion in 2021, well over a year later.

An exception to the one-year time bar is when the judgment and sentence is facially invalid.

RCW 10.73.090(1). A judgment and sentence may be facially invalid if the trial court calculated

the defendant’s offender score using a conviction that Blake voided. State v. Pascuzzi, 29 Wn.

App. 2d 528, 532, 541 P.3d 415, review denied, 3 Wn.3d 1007 (2024).

III. DE NOVO RESENTENCING

In general, when a facially invalid judgment and sentence is vacated, the defendant is

entitled to a full de novo resentencing hearing. State v. Vasquez, 4 Wn.3d 208, 216, 560 P.3d 853

(2024). But resentencing may not be the correct remedy for a facially invalid judgment and

sentence when the invalidity can be cured by correcting the judgment and sentence. State v. Kelly,

4 Wn.3d 170, 190, 561 P.3d 246 (2024).

In Kelly, the trial court determined that Blake caused prejudice to only Kelly’s actual

conviction for unlawful possession of a controlled substance, not to the sentences on his remaining

convictions. Id. at 176-77. The Supreme Court agreed that because Kelly’s high offender score

did not cause his standard sentencing range to change, the inclusion of the Blake point in his

offender scores was not material to his sentences. Id. at 182-85.

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Related

State v. Lamb
285 P.3d 27 (Washington Supreme Court, 2012)
State Of Washington, V. Anthony Joseph Pascuzzi
541 P.3d 415 (Court of Appeals of Washington, 2024)
State v. Vasquez
560 P.3d 853 (Washington Supreme Court, 2024)
State v. Kelly
561 P.3d 246 (Washington Supreme Court, 2024)
State v. Waller
Washington Supreme Court, 2021
State v. Blake
Washington Supreme Court, 2021
State v. McWhorter
Washington Supreme Court, 2023

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State of Washington v. Max William Jaynes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-max-william-jaynes-washctapp-2026.