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Washington Appellate Court: Personal Restraint Petition Proper Vehicle to Challenge Community Supervision
Loaded on June 1, 2025
by David Reutter
published in Prison Legal News
June, 2025, page 57
Filed under:
Conditions of,
Supervised Release - Conditions of,
Long-term Bans,
Unreasonable Conditions.
Location:
Washington.
On December 17, 2024, the Court of Appeals of the State of Washington, Division II, held that a trial court lacked personal jurisdiction over the state Department of Corrections (DOC) and dismissed a motion to enforce a released prisoner’s community custody condition. The Court concluded with an important warning …
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More from this issue:
- Washington’s Continuing Competency Crisis Strains Jails
- Rejected by Conviction Integrity Unit, 27 New York Prisoners Exonerated Anyway
- From the Editor, by Paul Wright
- $2.4 Million Settlement Reached After Elderly Pretrial Detainee Strangled by Cellmate in San Antonio Jail, by David Reutter
- Oklahoma Supreme Court Kills One Jail Death Suit, Threatening Settlement of Another
- Arkansas DOC Settles Retaliation Claim by Prisoner Who Also Won Back Confiscated COVID-19 Stimulus
- Kansas Supreme Court Revives Prisoner’s Challenge to Loss of Parental Rights, by Matthew Clarke
- Rural Virginia Jury Refuses to Hold Guards Liable for State Prisoner’s Death
- French Prisons Targeted in Coordinated Attack
- Mississippi DOC Issues Almost $300 Million in No-Bid Contracts to VitalCore Health
- Top Rikers Island Jailers Logged Overtime Equal to 14-Hour Days With No Days Off
- Fifth Circuit Refuses to Stop Court-Ordered Construction of Mental Health Facility at New Orleans Jail, by Boris Bastidas
- Ninth Circuit Revives Complaint Over Sloppy Cell Checks Before Psychotic Detainee’s Death at L.A. Jail, by Douglas Ankney
- $875,000 Award for Illinois Prisoner’s Delay in Getting Hernia Surgery, by David M. Reutter
- Salvadoran President’s Dark Secret Allegedly Behind Deal to Hold Deported Migrants in “Mega” Prison
- California Appellate Court: Custody Credits Must be Applied to Concurrent Terms in Multiple Open Cases, by David M. Reutter
- Over $1.1 Million Recovered for Rikers Island Janitors
- Four Arizona Prisoners Dead After Being Celled with Leader of 2004 Standoff
- Former Centurion Owner Accused of Helping Florida Governor Kill Legalized Weed
- $100,000 Settlement Reached For Tennessee Detainee Baptized to Get Out of Traffic Ticket, by Boris Bastidas
- Sixth Circuit Limits Deliberate Indifference Standard in Kentucky Jail Medical Care Challenge, by David M. Reutter
- Italy Begins Conjugal Visits in Prison “Sex Rooms”
- Auburn University’s Prison Education Program ‘Indefinitely Suspended’, by Charlotte West
- New Mexico Watchdog Group Sues for Video Allegedly Showing Jailers Killing Detainee, by David M. Reutter
- Gay Tennessee Prisoner Refuses to Out Himself in PREA Classification Hearings
- $500,000 for Colorado Detainee Dropped On His Face by Jailers, by Douglas Ankney
- Three New York Guards Plead Guilty to Beating Black Prisoner in “George Floyd Challenge”
- Ninth Circuit Reinstates Religious Exercise Claim from Arizona “Christian-Israelite” Prisoner Denied Passover Meal, by Michael Thompson
- Watchdogs Fault Nebraska Prisons for Suicide Response, Overpaid Staff, by Boris Bastidas
- Smart Communications Files for Bankruptcy Protection
- 11th Alabama Sheriff’s Employee Pleads Guilty in Jail Detainee’s Death, Admits Stomping Him in Genitals
- Second South Carolina Prisoner Executed by Firing Squad
- Tenth Circuit Upholds Nearly $8.8 Million Judgment for Utah Jail Death, by Douglas Ankney
- Fifth Circuit Reinstates Baha’i Texas Prisoner’s Dietary Claim, by Matthew Clarke
- Seven TDCJ Prison Guards Arrested in Alleged Smuggling Ring
- $62,500 For Idaho Prisoner Raped by Guard Who Later Committed Suicide, by Anthony Accurso
- Eighth Circuit Excuses Missouri Prisoner’s Failure to Exhaust Remedies While He Was In a Coma, by Douglas Ankney
- GTL/ViaPath Ordered to Pay $3 Million for Violations of Consumer Protection Laws
- Federal Court Blocks Idaho Executions Until Media Access Improves
- Former Wisconsin Warden Gets No Cell Time, $500 Fine After Prisoner Deaths
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- Government Quasi-Agency Attempts to Infiltrate Criminal Justice Nonprofit
- $7.75 Million Settlement for Exonerated North Carolina Prisoner, by David M. Reutter
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- New York Lowers Minimum Age for Prison Guards
- $13 Million Awarded to Exonerated Massachusetts Prisoner for Wrongful Conviction, by David M. Reutter
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- Eighth Circuit Lets Missouri Guard Skate For Placing Avowed Enemies In Same Cell, Resulting In Assault, by Anthony Accurso
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- Kansas Pays $150,000 for Prisoner Killed by Cellmate, Centurion Settlement Confidential
- $52,500 for Trans Florida Prisoner Sexually Assaulted by Cellmate
- Wellpath and VitalCore Skip Paying Nearly $2 Million in Settlements in South Carolina
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- Washington Appellate Court: Personal Restraint Petition Proper Vehicle to Challenge Community Supervision, by David Reutter
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- Trio of Guards Fired and Arrested for Smuggling at Louisiana Jails
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- News in Brief
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More from David Reutter:
- Sixth Circuit Announces State-Law Exceptions to Appeal Deadlines Preserve “Pending” Status Under AEDPA, Holding Belated-Appeal Procedures Toll Federal Habeas Limitations Period, April 1, 2026
- Florida Supreme Court Announces Rule 3.170(f)’s Good-Cause Plea-Withdrawal Standard Does Not Apply at Post-Appeal Resentencing, April 1, 2026
- Colorado Supreme Court Announces Defendant Must Be Competent Before Undergoing Mental-Condition Examination Under § 16-8-107(3)(b), April 1, 2026
- California Court of Appeal Announces Plea Agreements Cannot Bar § 1172.1 Resentencing, Holds Merit-Based Denial of Petition Is Appealable, April 1, 2026
- Georgia Supreme Court Clarifies That Failure to Object to Ineligible Juror Does Not Constitute Waiver Unless Party Knew or Could Have Discovered Ineligibility Through Ordinary Diligence, April 1, 2026
- Washington State Guard’s Conviction Affirmed in Self-Inflicted Gunshot Wound Scheme, March 1, 2026
- Massachusetts Supreme Judicial Court Holds Motion Judge Abused Discretion by Denying Evidentiary Hearing on IAC Claim Where Plea Counsel’s Affidavit Was Not Inherently Inconsistent With Colloquy Statements Regarding Immigration Advice, March 1, 2026
- Washington Supreme Court Clarifies Double Jeopardy Analysis for Multiple Assault Convictions, Holding That Assaultive Acts Occurring Over Short Time Period in Same Location Without Intervening Events Constitute Single Course of Conduct, March 1, 2026
- New Jersey Supreme Court Reverses Drug Convictions Under Cumulative Error Doctrine, Holding Combined Effect of Improper References to Television Series, Gun Violence, and Search Warrants Deprived Defendant of Fair Trial, March 1, 2026
- New York Court of Appeals Announces Coercive Police Tactics Compelling Suspect to Exit Home Constitute “Constructive Entry” Violating Payton, Holds Attenuation Analysis Applies to Third-Party Consent, March 1, 2026
More from these topics:
- Fourth Circuit Clarifies Revocation Appeal Provides “Procedurally Appropriate Mechanism” for Raising Rogers Challenge to Unannounced Supervised Release Conditions, Vacates Revocation Judgment Based on Null Standard Conditions, March 1, 2026. Waiver of Appeal Rights, Failure to Object, Revocation Proceedings, Conditions of, Plain Error.
- Massachusetts Supreme Judicial Court Announces Duration of GPS Monitoring Must Be Considered in Individualized Reasonableness Determination and Resulting Monitoring Period May Be Shorter Than Probationary Term, Jan. 1, 2026. Parole/Probation Searches, Condition of Probation, GPS Tracking Device, State Constitutional Claims, Conditions of.
- Slender Man Stabber’s Escape Prompts “Serious Questions” for Wisconsin DOC, Jan. 1, 2026. Escapes, Electronic Monitoring, Conditions of.
- Jailhouse Lawyer Gets 16-1/2-Year Sentence for Defrauding Prisoner “Clients”, Nov. 1, 2025. Prisoner Legal Assistance, Restitution, Forfeiture, Revocation/Modification of Probation, etc., Fraud and Deceit, Conditions of.
- The Rise of Mass Supervision: From Rehabilitative Alternative to Shadow Carceral State, Oct. 1, 2024. Probation, Parole & Supervised Release, Supervised Release - Conditions of.
- Alabama Denies Parole to Dead Prisoner, Aug. 15, 2024. Wrongful Death, Conditions of, Sentences - Length/Severity of, Compassionate Release.
- How Parole and Probation “No-Association” Conditions Hamper Successful Reentry, June 1, 2024. Commentary/Reviews, Conditions of.
- Electronic Monitoring: An Alternative to Incarceration or a Troubling Extension of Punishment?, April 15, 2024. Commentary/Reviews, Statistics/Trends, Electronic Monitoring, Electronic Surveillance, Bail/Pretrial Release, Conditions of.
- Parole and Probation Accused of Driving Prison Growth, April 1, 2024. Commentary/Reviews, Statistics/Trends, Probation, Parole & Supervised Release, Conditions of.
- North Carolina Court of Appeals Reinstates Parolee’s Parental Rights, Says Parole Conditions Barred Him from Visiting Minor Daughter, April 1, 2024. Parole Conditions, Fathers in Prison, Parental rights, Conditions of.

