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STATE v. DUNAWAY

Nos. 53482-9, 53574-4.

109 Wn.2d 207 (1987)

743 P.2d 1237

THE STATE OF WASHINGTON, Petitioner, v. JAMES T. DUNAWAY, Respondent. THE STATE OF WASHINGTON, Petitioner, v. RAYMOND PATRICK GREEN, Respondent. THE STATE OF WASHINGTON, Petitioner, v. JOHN CLARENCE FRANKLIN, Respondent.

The Supreme Court of Washington, En Banc.

As amended by order January 28, 1988.

Attorney(s) appearing for the Case

Seth R. Dawson, Prosecuting Attorney for Snohomish County, and Seth Aaron Fine, Deputy; Donald C. Brockett, Prosecuting Attorney for Spokane County, and Clark D. Colwell, Deputy, for petitioner.

Richard L. Cease, Public Defender, and Jim Kane, Assistant, for respondent Green.

Frank Conklin, Special Public Defender, for respondent Franklin.

[As amended by order of the Supreme Court January 28, 1988.]

DURHAM, J.

These three cases involve interpretation of the Sentencing Reform Act of 1981 (SRA) relating to the calculation of a defendant's standard sentence range. One of the factors in that calculation is the defendant's offender score, which measures the length and severity of his criminal history. The SRA, RCW 9.94A, provides that separate crimes encompassing "the same criminal conduct" must...

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