State Of Washington, V. Theophilus Williamson

CourtCourt of Appeals of Washington
DecidedSeptember 29, 2025
Docket86391-6
StatusUnpublished

This text of State Of Washington, V. Theophilus Williamson (State Of Washington, V. Theophilus Williamson) 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.

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State Of Washington, V. Theophilus Williamson, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 86391-6-I Respondent,

v. DIVISION ONE

THEOPHILUS D. WILLIAMSON, UNPUBLISHED OPINION Appellant.

CHUNG, J. — On February 7, 2024, Theophilus Williamson pleaded guilty to

misdemeanor violation of a court order. He later moved to withdraw his guilty plea on

the basis of voluntariness, then withdrew that motion. On appeal, Williamson asks this

court to remand to the trial court to “allow him to decide whether to withdraw his plea

deal.” Williamson contends that his plea was involuntary because there was an

insufficient factual basis on the record for his plea and it was involuntary under the

circumstances. We disagree and affirm.

FACTS

On May 8, 2023, the King County Superior Court issued a no-contact order

prohibiting Williamson from “knowingly coming within, or knowingly remaining within, a

specified distance” of a protected party. Williamson was charged with violating that

order on May 11, 2023 and was subsequently arrested.

While Williamson was in custody and through the beginning of his trial, his case

was repeatedly continued, often with his objection and assertion of his speedy trial No. 86391-6-I/2

rights. Additionally, he was reassigned counsel multiple times, further delaying his trial.

Because Williamson had two ongoing cases and the same lawyer represented him on

both matters, each time an attorney was reassigned, they were reassigned on both of

Williamson’s cases, including the instant case.

In the middle of jury selection, Williamson moved to represent himself. At the

recommendation of the court, Williamson allowed his counsel to finish jury selection. He

then requested to be absent from jury selection so he could prepare for trial. The next

day, Williamson’s counsel informed the court that the parties had reached a plea

agreement. The parties jointly moved to amend the information from a felony violation of

a court order to a misdemeanor violation of a court order. The amended information

stated the issuance date of the violated court order as “May 11, 2023,” rather than “May

8, 2023,” as the initial information stated. The court subsequently engaged in a plea

colloquy with Williamson virtually. On February 7, 2024, Williamson pleaded guilty and

was sentenced to a misdemeanor violation of a court order. 1 Thirteen days later, on

February 20, 2024, Williamson filed a motion to withdraw his guilty plea. Over a month

later, on March 27, 2024, he withdrew that motion, and the trial court did not rule on it.

Williamson now appeals the voluntariness of his plea.

DISCUSSION

On appeal, Williamson argues that his plea was involuntary because there was

no factual basis for “the crime as charged.” He further contends that he made his plea

1 The colloquy occurred virtually because of a disagreement between jail staff and Williamson

regarding transportation to court.

2 No. 86391-6-I/3

involuntarily because of frequent reassignment of counsel and because his plea

colloquy occurred virtually. 2 We disagree.

First, Williamson conflates two separate rules concerning pleas, one procedural

and one constitutional. CrR 4.2(d) governs guilty pleas and states as follows:

The court shall not accept a plea of guilty, without first determining that it is made voluntarily, competently and with an understanding of the nature of the charge and the consequences of the plea. The court shall not enter a judgment upon a plea of guilty unless it is satisfied that there is a factual basis for the plea.

Thus, CrR 4.2(d) requires both voluntariness and a factual basis for a plea on the

record. However, the requirement that “a trial court must be satisfied that there is a

factual basis for a defendant’s guilty plea . . . is a procedural requirement that is not

constitutionally mandated.” State v. Bird, 187 Wn. App. 942, 945, 352 P.3d 215 (2015).

Failure to adhere to a technical requirement under CrR 4.2 “does not in itself result in a

constitutional violation or amount to a manifest injustice.” State v. Branch, 129 Wn.2d

635, 642, 919 P.2d 1228 (1996). 3 See also In re Pers. Restraint of Hilyard, 39 Wn. App.

723, 727, 695 P.2d 596 (1985) (“The duty imposed by court rule that the judge must be

satisfied of the plea's factual basis should not be confused with the constitutional

requirement that the accused have an understanding of the nature of the charge.”).

2 The State argues that this court “should reject . . . outright” Williamson’s claim that his plea was

involuntary under the circumstances because that aspect of involuntariness was not raised in the assignment of error. Our Supreme Court has previously stated, In a case where the nature of the appeal is clear and the relevant issues are argued in the body of the brief and citations are supplied so that the Court is not greatly inconvenienced and the respondent is not prejudiced, there is no compelling reason for the appellate court not to exercise its discretion to consider the merits of the case or issue. State v. Olson, 126 Wn.2d 315, 323, 893 P.2d 629 (1995); see also Hadley v. Maxwell, 144 Wn.2d 306, 311 n.1, 27 P.3d 600 (2001) (citing Olson, 126 Wn.2d at 318-19). We exercise our discretion here to consider the merits of Williamson’s claim that his plea was involuntary. 3 Appellant argues that the analysis from Branch is inapposite here because Branch concerned a

purported violation of CrR 4.2(g). But we have also applied the Branch ruling to alleged CrR 4.2(d) violations. See Bird, 187 Wn. App. at 945.

3 No. 86391-6-I/4

Williamson contends that his plea was involuntary because there is no factual

basis for the amended charge, as the amended information charges Williamson with

violation of a non-existent no-contact order dated May 11, 2023. Accordingly,

Williamson’s contention concerns only procedural error, not constitutional error.

Here, there was no procedural error. CrR 4.2(d) does not require the factual

basis for the plea to arise solely from the amended charge as written. Rather, the

factual basis for the plea can arise from any reliable source on the record. State v.

Osborne, 102 Wn.2d 87, 95, 684 P.2d 683 (1984); State v. Newton, 87 Wn.2d 363, 370-

71, 552 P.2d 682 (1976). In this case, the record demonstrates a clear factual basis for

the plea. The prosecutor’s summary correctly cites to the May 8, 2023, protection order

as the one that Williamson violated. The record contains the original information with the

correct date for the protection order that was alleged to have been violated, May 8.

Further, in his written plea agreement, Williamson wrote that “On May 11, 2023, in King

County, Washington, I knew of and willfully violated the terms of a Court Order issued

on May 8, 2023, under RCW chapter 7.105.” (Emphasis added). And during the plea

colloquy, the trial court read this statement from the written plea agreement back to

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Related

In Re the Personal Restraint of Hilyard
695 P.2d 596 (Court of Appeals of Washington, 1985)
State v. Newton
552 P.2d 682 (Washington Supreme Court, 1976)
State v. Branch
919 P.2d 1228 (Washington Supreme Court, 1996)
State v. Olson
893 P.2d 629 (Washington Supreme Court, 1995)
State v. Osborne
684 P.2d 683 (Washington Supreme Court, 1984)
State v. Williams
71 P.3d 686 (Court of Appeals of Washington, 2003)
Hadley v. Maxwell
27 P.3d 600 (Washington Supreme Court, 2001)
Hadley v. Maxwell
144 Wash. 2d 306 (Washington Supreme Court, 2001)
State v. Williams
117 Wash. App. 390 (Court of Appeals of Washington, 2003)
State v. Bird
352 P.3d 215 (Court of Appeals of Washington, 2015)

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