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STATE v. CRAWFORD

No. 67169-3-I.

267 P.3d 365 (2011)

164 Wash.App. 617

STATE of Washington, Respondent, v. Michael David CRAWFORD, Appellant. In the Matter of the Personal Restraint of Michael David Crawford.

Court of Appeals of Washington, Division 1.

Publication Ordered November 7, 2011.

Attorney(s) appearing for the Case

Thomas Edward Doyle , Attorney at Law, Hansville, WA, for Appellant.

Michael David Crawford , Aberdeen, WA, Petitioner Pro Se.

John C. Skinder , Carol L. La Verne, Thurston County Prosecutor's Office, Olympia, WA, for Respondent.

BECKER, J.

¶ 1 Community custody is a portion of an offender's sentence that is served in the community. Therefore, an offender is not under community custody while in jail. Because appellant was not under community custody when he committed the crime, it was error to add an extra point to his offender score.

¶ 2 Michael Crawford was convicted of assault in 2005 and sentenced to prison. He was released in September 2008 and began serving a term of...

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