Facts:  Petitioner Jeffrey Coats was convicted of first degree robbery, conspiracy to commit first degree robbery, and conspiracy to commit first degree murder in the Superior Court for Pierce County and received three standard range sentences to be served concurrently.  Fourteen years later, Coats filed a personal restraint petition in the Washington Court of Appeals.  Coats asserted that his judgment and sentence were invalid on their face insofar as the judgment erroneously stated that the maximum penalty for conspiracy to commit first degree robbery is life in prison.  The Washington Court of Appeals dismissed the petition, holding that the error was a technical misstatement that had no effect upon Coats’ rights.  Coats appealed this decision to the Supreme Court of Washington.

Question(s):  Did the misstatement of the maximum penalty for conspiracy to commit first degree robbery in Coats’ judgment render it invalid on its face?

Conclusion:  Justice Chambers’ opinion for the Court affirmed the Washington Court of Appeals, concluding that under Washington Revised Code §10.73.090 a judgment and sentence are invalid on their face only when the trial court has exceeded its sentencing authority.  Thus, as Coats’ sentence for conspiracy to commit first degree robbery was within the standard sentencing range for the crime despite the misstatement of the maximum penalty for the crime, Coats’ judgment and sentence were valid.

Docket No. 83544-6 (from Court of Appeals Division II Case No. 38894-4)

Petitioner: Jeffrey Coats

(Counsel: Jeffrey Erwin Ellis)

Respondent: State of Washington

(Counsel: Kathleen Proctor)

Briefs:

Argument: Thursday, January 20, 2011 2:30pm

[Source: TVW, http://tvw.org]

Decided: Thursday, November 17th, 2011

Prevailing Party: State of Washington (Respondent)

Vote: 9-0

Citation: Pending

Court: Madsen2 Court (2011-)

Madsen
(Concurs)

Johnson

Alexander

Chambers
(Majority)

Owens

Fairhurst

Johnson

Stephens
(Concurs)

Wiggins