STATE v. BRINKLEY

No. 72852-1-I.

369 P.3d 157 (2016)

192 Wash.App. 456

STATE of Washington, Respondent, v. Jeffrey Lafate BRINKLEY, Appellant.

Court of Appeals of Washington, Division 1.

February 1, 2016.


Attorney(s) appearing for the Case

Nielsen Broman Koch PLLC, Attorney at Law, Eric J. Nielsen , Jennifer M. Winider , Nielsen Broman & Koch PLLC, Seattle, WA, for Appellant.

Mary Kathleen Webber , Seth Aaron Fine , Snohomish County Prosecutors Office, Everett, WA, for Respondent.


¶ 1 Appellant Jeffrey Brinkley was sentenced under the Persistent Offender Accountability Act (POAA), Washington's "three strikes" recidivism law. Brinkley claims the trial court erred when it determined the "temporal relationship" of his prior convictions, in violation of the rule that "[o]ther than the fact of a prior conviction,...

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