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On December 11, 2025, the Supreme Court of Washington issued its opinion in State v. Danielson, Docket No. 103627‑2, a case involving constitutional challenges to how legal financial obligations (LFOs) are reimbursed after a conviction is vacated. This decision addresses both equal protection and how community service work performed in lieu of monetary payments should be treated under Washington law. Washington Courts+1

Background: LFOs, Vacated Convictions, and Reimbursement

In 2021, the Washington Supreme Court held in State v. Blake that RCW 69.50.4013 — the statute criminalizing simple drug possession — was unconstitutional and void. As a consequence, prior convictions under that statute could be vacated and defendants could seek refunds for LFOs they paid. State Court Report

In Danielson, Sabra Danielson (and relatedly Simone Nelson) had convictions vacated under Blake. They each had legal financial obligations imposed as part of their sentences. Part of their satisfaction of those obligations came from community service work (CSW), rather than cash payments. After vacating the convictions, Danielson sought reimbursement not only for cash payments she made but also for the value of her community service work that had been credited toward her LFOs. State Court Report

The core constitutional question before the Supreme Court was whether the State’s refusal to reimburse the monetary value of community service work — when other people who paid their LFOs in cash received refunds — violated the Equal Protection Clause of the United States and Washington constitutions. Washington Courts

Under equal protection principles, the government must treat similarly situated individuals alike unless there is a legitimate reason for differential treatment. Danielson argued that those who could afford to pay LFOs in cash received reimbursements after their convictions were vacated, while those who used community service due to lack of ability to pay were denied similar reimbursement — amounting to discrimination based on wealth or indigency. State Court Report

Supreme Court’s Holding

The Washington Supreme Court rejected Danielson’s equal protection claim, holding that she failed to show that she and others in similar situations were treated differently because of their indigency or economic status. The Court emphasized several points:

• Lack of Disparate Treatment Based on Wealth

The Court found that reimbursement was tied to statutory programs and not intended to favor wealthier individuals. Danielson and Nelson did not demonstrate that similarly situated people who used community service to satisfy LFOs andhad their convictions vacated were reimbursed differently solely because they lacked the ability to pay in cash. Thus, the claim did not show intentional or purposeful discrimination against indigent persons. State Court Report

• State Action and Community Service

The Court also addressed whether community service work performed for nonprofit organizations constituted state action for purposes of equal protection. Here, the record did not support that the performance of community service itself was state action in a way that would trigger heightened scrutiny. Community service in these cases was performed outside direct state employment or control, diminishing the basis for an equal protection violation on that ground. waprosecutors.org

In short, the majority concluded that refusing to reimburse the monetary value of community service hours did not amount to unconstitutional unequal treatment simply because a defendant did not have the ability to pay. Washington Courts

Implications of the Decision

State v. Danielson provides important guidance on how Washington courts will approach constitutional challenges connected to legal financial obligations and the broader consequences of vacated convictions:

  • Equal protection claims require clear evidence of disparate treatment due to a protected characteristic or fundamental right. Mere differences in outcome due to statutory structure are not sufficient.
  • Community service work, while valuable in satisfying court‑ordered obligations, does not necessarily translate into an equal financial interest that must be reimbursed by the State after a conviction is voided.
  • Challenges to statutory frameworks for LFO reimbursements must be carefully framed within established constitutional analysis rather than generalized claims about economic inequality.

What This Means for Defendants Seeking Reimbursements

Defendants hoping to recover the value of community service hours after vacated convictions should be aware that:

  • The Court has drawn a line between cash reimbursements and community service performed to satisfy judicial financial orders.
  • Even after a conviction is invalidated, reimbursement frameworks are interpreted strictly according to statutory and constitutional standards.
  • Indigency alone, without evidence of disparate treatment relative to a similarly situated group, may not suffice for a successful constitutional claim.

For anyone considering motions related to Blake vacaturs or reimbursement of LFOs, understanding how courts treat these financial components remains crucial.

Contact Blanford Law today at ken@blanfordlaw.com or 253‑720‑9304 for guidance on your legal matter.

We are actively helping individuals seek relief and reimbursement related to Blake vacaturs and legal financial obligations.

Additional Resources

Helpful related articles to support your understanding of legal financial obligations, vacating convictions, and community service in Washington law:

  1. RCW 9A.16.046 – Washington Law on Legal Financial Obligations — Explains Washington’s statute that governs how legal financial obligations (LFOs) are imposed and revised, including credit for community service.
    🔗 https://blanfordlaw.com/rcw-9a-16-046-washington-law/
  2. Vacating a Conviction – RCW 9.96.060 — Reviews the process for vacating criminal convictions in Washington under RCW 9.96.060, including eligibility and effects.
    🔗 https://blanfordlaw.com/vacating-conviction-rcw-9-96-060/
  3. Pierce County Community Service Sites — A resource listing approved community service locations in Pierce County that may be used to satisfy court‑ordered requirements.
    🔗 https://blanfordlaw.com/pierce-county-community-service-sites/
  4. Alternative Confinement Exclusion List – Pierce County, Washington — Details the exclusion list for alternative confinement programs in Pierce County, outlining what settings are not allowed for community service or alternate sentencing.
    🔗 https://blanfordlaw.com/54-alternative-confinement-exclusion-list-pierce-county-washington/
  5. Snohomish County Bail Process – A Complete Guide to Posting Bail — Explains the bail process in Snohomish County, including how bail is set, posted, and what happens after release.
    🔗 https://blanfordlaw.com/snohomish-county-bail-process-a-complete-guide-to-posting-bail/