In the recent State of Washington v. Christopher Lee Olsen (No. 102131-3) decision, the Washington Supreme Court addressed whether the landmark State v. Blake ruling, which declared the state’s strict liability drug possession statute unconstitutional, allows defendants to withdraw guilty pleas entered before the 2021 Blake decision. Christopher Lee Olsen, the petitioner, sought to vacate all his guilty pleas following the vacating of his drug possession convictions under Blake. However, the court ultimately held that Olsen’s challenge was time-barred under RCW 10.73.090 and upheld the lower court’s decision.
Case Background: Guilty Pleas and Blake Impact
Christopher Lee Olsen pleaded guilty to multiple offenses, including unlawful possession of a controlled substance, in 2003 and 2006. After serving his sentences, Olsen was later convicted of first-degree murder. Following the 2021 State v. Blake ruling, Olsen sought to withdraw his guilty pleas to all charges, claiming that his guilty pleas were involuntary since drug possession was later deemed a “nonexistent crime.” The trial court vacated his drug possession convictions but denied the motion to withdraw the remaining guilty pleas.
Olsen argued that his plea agreements were “indivisible”—meaning that vacating one guilty plea should require vacating the others. The Court of Appeals disagreed, affirming the trial court’s decision, and Olsen’s case was subsequently reviewed by the Washington Supreme Court.
Washington Supreme Court Ruling: Time-Barred Challenge to Guilty Pleas
In its ruling, the Washington Supreme Court held that Olsen’s motions to withdraw his guilty pleas were time-barred under RCW 10.73.090, which requires defendants to file challenges within one year of a judgment becoming final. While the Blake decision invalidated the drug possession statute and allowed the vacating of Olsen’s drug possession convictions, it did not retroactively render his guilty pleas involuntary or unknowing. The court emphasized that at the time Olsen entered his guilty pleas, they were considered valid under the existing law, and the later ruling in Blake did not provide new grounds for withdrawing them.
Additionally, the court rejected Olsen’s argument regarding indivisible plea agreements. The court found that Olsen failed to demonstrate that the 2003 and 2006 pleas were part of an indivisible package deal that would necessitate withdrawing all the pleas based on the vacating of the drug possession convictions.
Conclusion
The Washington Supreme Court’s decision in State v. Olsen underscores the importance of time limits on collateral attacks under RCW 10.73.090. The court ruled that the Blake decision, while significant in vacating drug possession convictions, does not allow untimely challenges to guilty pleas that were considered valid at the time they were made. Olsen’s claim that his guilty pleas were involuntary was dismissed as time-barred, and the court upheld the trial court’s denial of his motion to withdraw the pleas.
For more details, you can read the full opinion here: Washington Supreme Court Opinion – State v. Olsen.
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