Zachary Rosenthal v. Warden, Washington State Corrections Center (Shelton)

CourtDistrict Court, W.D. Washington
DecidedMay 12, 2026
Docket3:26-cv-05000
StatusUnknown

This text of Zachary Rosenthal v. Warden, Washington State Corrections Center (Shelton) (Zachary Rosenthal v. Warden, Washington State Corrections Center (Shelton)) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Zachary Rosenthal v. Warden, Washington State Corrections Center (Shelton), (W.D. Wash. 2026).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 ZACHARY ROSENTHAL, 9 Petitioner, CASE NO. 3:26-cv-05000-BHS-BAT 10 v. REPORT AND RECOMMENDATION 11 WARDEN, WASHINGTON STATE CORRECTIONS CENTER (SHELTON), 12 R d t

13 Petitioner seeks 28 U.S.C. § 2254 habeas relief from his convictions for three counts of 14 vehicular Assault and one count of felony hit and run in Lewis County Superior Court case 15 number 23-1-00295-21. Dkt. 1. For the reasons below, the Court recommends denying the 16 habeas petition and DISMISSING this case with prejudice. If this recommendation is adopted, 17 the Court recommends issuance of a certificate of appealability be DENIED. 18 BACKGROUND 19 A. Habeas Petition 20 Petitioner originally raised ten grounds for habeas relief revolving around the claim he 21 was denied his Sixth Amendment right to counsel during in his state criminal proceedings. Dkt. 22 1. After Respondent contended most of the federal habeas claims were unexhausted, Petitioner 23 filed a “Notice” in which he stated: “Petitioner elects to proceed solely on the properly exhausted 1 Sixth Amendment denial-of-counsel claim and voluntarily withdraws any unexhausted claims. 2 Dkt. 13 at 1. The Court accordingly found the only habeas grounds for relief that were before the 3 Court were: claim 5 (“Failure to Timely Appoint Counsel Structural Sixth Amendment 4 Violation”); claim 6 (“Complete Denial of Counsel Structural Sixth Amendment Violation”);

5 and claim 7 (“Failure to timely appoint counsel.”) See Dkt. 14 (referring to habeas petition, Dkt. 6 1 at 6, 8, and 9). 7 Because Respondent acknowledges the habeas petition is timely and Petitioner’s claim 8 his Sixth Amendment right to counsel is exhausted, the state procedural history need not be 9 recited. 10 B. State Court Findings 11 Petitioner filed a direct appeal in the Washington Court of Appeals. In State v. Rosenthal, 12 34 Wn.App.2d 1016, 2025 WL 1043370 at * 1-3 (Wash. Div. II, April 8, 2025) the Washington 13 Court of Appeals made the following findings of fact relevant to Petitioner’s Sixth Amendment 14 claims:

15 FACTS 16 Rosenthal caused a collision by veering his pickup truck into oncoming traffic and striking a car with three people in it. 17 Rosenthal then fled the scene. Rosenthal was on methamphetamine at the time. The State charged Rosenthal by amended information 18 with three counts of vehicular assault while under the influence and one count of felony hit and run. 19 A. Preliminary Proceedings 20 Rosenthal was appointed his first attorney at a preliminary hearing 21 on May 30, 2023. The first attorney represented Rosenthal at his arraignment on an amended information on June 8, where 22 Rosenthal attempted to raise a speedy arraignment objection, but his first attorney informed Rosenthal that there was no violation. 23 Rosenthal's trial was set for the week of July 24. 1 At an omnibus hearing on June 29, Rosenthal raised a conflict of interest issue relating to his first attorney. The trial court instructed 2 Rosenthal to file a motion on the issue. 3 On July 6, Rosenthal filed a pro se motion for new counsel, claiming that the first attorney had testified against him in a prior 4 bail jumping case. On July 13, at the hearing on Rosenthal's motion, the first attorney explained that he answered questions 5 from the trial court in a prior case, and he stated that he had already spoken to all but one of the witnesses in Rosenthal’s 6 current case, discussed every aspect of the case with Rosenthal, and was ready to proceed to trial in Rosenthal's current case. At 7 Rosenthal’s insistence, the trial court directed the first attorney to withdraw and appointed Rosenthal new counsel. Rosenthal’s 8 second attorney was appointed the next day. 9 At a hearing on July 27, Rosenthal’s second attorney informed the court that Rosenthal told him that “he would be claiming that 10 someone else committed a particular crime.” Verbatim Rep. of Proc. (VRP) (July 27, 2023) at 30. That other person was also the 11 second attorney’s client, which created a conflict of interest for the attorney. Accordingly, the second attorney asked to be allowed to 12 withdraw from Rosenthal’s case. Due to the conflict, the trial court allowed the second attorney to withdraw, which reset Rosenthal’s 13 time for trial under CrR 3.3 to expire on September 25, 2023, 60 days later. 14 At a hearing on August 2, Lewis County's defense coordinator 15 explained to the trial court that Rosenthal had conflicts with all of the attorneys who had public defense contracts in Lewis County, 16 so she was attempting to hire an attorney from outside that contracted attorney pool to represent Rosenthal. This attorney, 17 Rosenthal’s third, was on vacation at the time. Rosenthal orally moved to dismiss his case, but the court declined to consider this 18 motion until Rosenthal had counsel assigned or formally decided to proceed as a self-represented litigant. 19 On August 3, the third attorney (trial counsel) accepted the 20 appointment to represent Rosenthal but, due to still being out of town, could not appear until August 17. The public defense 21 coordinator explained this situation to the trial court in a hearing on August 4. Rosenthal objected to the delay in appointing counsel 22 and argued that the case should be dismissed. The trial court observed that the delay was primarily caused by conflicts of 23 interest with the County’s panel of attorneys and the fact that “[i]t takes time to find people outside our panel.” 4 VRP (Aug. 4, 2023) 1 at 48. On August 7, Rosenthal filed a pro se CrR 8.3(b) motion to dismiss his case for government misconduct due to the public 2 defense coordinator’s delay in appointing him counsel. 3 When Rosenthal's trial counsel appeared on August 17, the deadline for Rosenthal’s CrR 3.3 time for trial was set to expire on 4 September 25, 2023. The trial court tried to set trial for the week before that expiration date, but trial counsel had scheduling 5 conflicts for much of September and observed that there were over 500 pages of discovery in the case. Rosenthal objected to waiving 6 his right to a speedy trial. As a result of the tension between trial counsel's ability to perform effectively and Rosenthal’s refusal to 7 continue the trial date, trial counsel asked the court to hear Rosenthal’s CrR 8.3(b) motion to help determine the outcome of 8 the case because trial counsel did not believe that he could represent Rosenthal effectively at any trial set in September 2023. 9 Rosenthal addressed the trial court directly to ask the court to dismiss his case due to the gap in representation between his 10 second attorney and trial counsel. 11 B. CRR 8.3 Hearing 12 At the hearing on the CrR 8.3(b) motion to dismiss, Rosenthal’s trial counsel presented Rosenthal’s arguments. The motion was 13 based on CrR 3.1, which requires a defendant to be represented at every stage of proceedings. Rosenthal argued that the fact he 14 lacked assigned counsel from July 27 to August 3 constituted government mismanagement that required the dismissal of his 15 case. Rosenthal also argued that his second attorney should not have been removed despite his conflict of interest, or that a 16 “temporary attorney” should have been appointed until new permanent defense counsel could be assigned. 1 VRP (Aug. 22, 17 2023) at 22. And Rosenthal argued that he was prejudiced because his trial counsel could not effectively prepare for trial between his 18 return from vacation and the expiration of Rosenthal's speedy trial right. 19 The State responded that Rosenthal was represented at every 20 critical stage of proceedings and could not demonstrate any violation of rights, so the lack of an attorney for about eight days 21 did not prejudice him.

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Zachary Rosenthal v. Warden, Washington State Corrections Center (Shelton), Counsel Stack Legal Research, https://law.counselstack.com/opinion/zachary-rosenthal-v-warden-washington-state-corrections-center-shelton-wawd-2026.