State Of Washington, V. Vincent E. Huff, Jr.

CourtCourt of Appeals of Washington
DecidedApril 21, 2025
Docket85795-9
StatusUnpublished

This text of State Of Washington, V. Vincent E. Huff, Jr. (State Of Washington, V. Vincent E. Huff, Jr.) 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. Vincent E. Huff, Jr., (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 85795-9-I Respondent, DIVISION ONE v. UNPUBLISHED OPINION VINCENT EDWARD HUFF, Jr.,

Appellant.

COBURN, J. — Vincent Huff, Jr. challenges his 2018 plea agreement because he

was not informed that the trial court had the discretion to impose a term of community

custody for the offense of assault in the second degree. The record demonstrates that

Huff was informed that the court could order community custody and he was not

affirmatively misled about a consequence of his plea. As there is no grounds to

withdraw his plea, we affirm the conviction but remand to strike the legal financial

obligations from his judgment and sentence.

FACTS

In May 2018, the State charged Huff with one count of rape of a child in the first

degree and one count of child molestation in the first degree. The parties “carefully

negotiated” a plea agreement in which Huff agreed to plead guilty pursuant to North 85795-9-I/2

Carolina v. Alford 1 to one count of assault in the second degree and pursuant to In re

Barr 2 and State v. Zhao 3 to one count of assault in the third degree. In exchange, the

State agreed to recommend a sentence of seven months of incarceration on each count

to be served concurrently.

At the plea hearing, Huff confirmed that he had read the plea agreement on his

own and with his attorney. During the colloquy, Huff expressed questions and confusion

about several issues which were addressed in private conversations with his counsel.

Huff stated that he understood the charges, the associated standard ranges and

maximum sentences, and that the judge was not required to accept the recommended

sentence. The trial court found that, based on Huff’s written statement and his answers

during the colloquy, the plea was knowingly, intelligently, and voluntarily made, Huff

understood the consequences of the plea, and there was a factual basis for the plea.

At the sentencing hearing, the trial court imposed the agreed recommendation of

seven months of confinement which amounted to his time already served in the King

County jail. In addition, the trial court noted that assault in the second degree “is a

violent crime . . . and does make Mr. Huff eligible for community custody for a period of

up to 12 months,” and exercised its discretion to impose this term of community

custody. The Department of Corrections subsequently determined that Huff was

ineligible for supervision and he was released from community custody in November

2018.

Huff filed a notice of appeal in August 2023. The appeal was untimely, but a

1 North Carolina v. Alford, 400 U.S. 25, 91 S. Ct. 160, 27 L. Ed. 2d 162 (1970). 2 In re Pers. Restraint of Barr, 102 Wn.2d 265, 684 P.2d 712 (1984). 3 State v. Zhao, 157 Wn.2d 188, 137 P.3d 835 (2006).

2 85795-9-I/3

commissioner of this court granted his motion to enlarge time to file the appeal.

DISCUSSION

Huff challenges his plea agreement, a community custody condition, and legal

financial obligations imposed at the time of his sentencing.

Withdrawal of Plea

Huff asserts that his guilty plea was invalid because he was affirmatively misled

about the community custody consequences of his plea. We disagree.

“Due process requires that a defendant’s guilty plea be knowing, voluntary, and

intelligent.” State v. Mendoza, 157 Wn.2d 582, 587, 141 P.3d 49 (2006). The defendant

must be informed of all direct consequences of the plea. State v. Gregg, 196 Wn.2d

473, 483, 474 P.3d 539 (2020). “[A] guilty plea may be deemed involuntary when based

on misinformation regarding a direct consequence on the plea.” 4 Mendoza, 157 Wn.2d

at 591. “Absent a showing that the defendant was correctly informed of all of the direct

consequences of his guilty plea, the defendant may move to withdraw the plea.” Id.

Here, Huff contends that he was affirmatively misled about the applicability of

community custody because the paragraphs pertaining to community custody were

crossed out in his guilty plea statement and he acknowledged that the paragraphs did

not apply to him. Huff is correct that section 6(f) concerning community custody was

struck from his guilt plea statement. The provision states, “[i]n addition to confinement, if

4 Both parties cite to State v. Ross, 129 Wn.2d 279, 280, 916 P.2d 405 (1996), which held that “mandatory community placement constitutes a direct consequence of a guilty plea and failure to so inform a defendant renders that plea invalid.” However, in this case, the term of community custody was discretionary under RCW 9.94A.702(c) rather than mandatory. Neither party discusses whether community custody imposed pursuant to the trial court’s discretion is a direct or collateral consequence of a plea and we make no determination as to whether Ross applies equally to discretionary terms of community custody. Rather, we resolve the merits of Huff’s claim on the factual argument provided by the parties. 3 85795-9-I/4

the total period of confinement ordered is more than 12 months, the judge will sentence

me to the following period of community custody, unless the judge finds substantial and

compelling reasons to do otherwise.” However, any standard range sentence imposed

by the trial court would not have met the parameters for community custody outlined in

6(f). Huff’s standard range sentence was six to 12 months of incarceration and the

agreed recommended sentence was seven months. During the plea colloquy, Huff

acknowledged that section (f) did not apply to him. Thus, the record does not support

Huff’s claim that the deletion of section 6(f) affirmatively misled him as to a direct

consequence of the plea agreement.

The statement on plea of guilty discloses that the trial court may impose

community custody. The provision 6(e), immediately above the struck language,

outlines aspects of sentencing other than confinement, including “[t]he judge may also

order that I pay a fine, court costs, attorney fees, and other costs and fees, and place

other restrictions and requirements upon me. Furthermore, the judge may place me on

community custody.” While Huff did not explicitly acknowledge that the judge could

order community custody, he confirmed his understanding that the court could impose

fines, costs and fees as detailed in the same provision of his guilty plea statement.

The possibility that the judge could place him on community custody was

included in the guilty plea statement that Huff acknowledged having reviewed by himself

and with his attorney. Moreover, when the court imposed community custody, Huff did

not express any confusion or objection. The record supports that Huff was informed that

the court could impose community custody as a consequence of his plea. As such, Huff

has not established a basis to withdraw his guilty plea.

4 85795-9-I/5

Community Custody Condition

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
In Re the Personal Restraint of Barr
684 P.2d 712 (Washington Supreme Court, 1984)
In Re Personal Restraint of Erickson
191 P.3d 917 (Court of Appeals of Washington, 2008)
State v. Zhao
137 P.3d 835 (Washington Supreme Court, 2006)
State v. Mendoza
141 P.3d 49 (Washington Supreme Court, 2006)
State v. Gregg
474 P.3d 539 (Washington Supreme Court, 2020)
State v. Ross
916 P.2d 405 (Washington Supreme Court, 1996)
State v. Bao Sheng Zhao
157 Wash. 2d 188 (Washington Supreme Court, 2006)
State v. Mendoza
141 P.3d 49 (Washington Supreme Court, 2006)
State v. Hunley
287 P.3d 584 (Washington Supreme Court, 2012)
In re the Personal Restraint of Erickson
146 Wash. App. 576 (Court of Appeals of Washington, 2008)
State Of Washington, V. James Laron Ellis
530 P.3d 1048 (Court of Appeals of Washington, 2023)

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