In the State of Washington v. Nicole Marie Willyard (No. 102325-1), the Washington Supreme Court addressed whether the landmark Blake decision, which ruled Washington’s drug possession statute unconstitutional, allows for untimely challenges to prior guilty pleas. Nicole Willyard sought to withdraw her guilty pleas for unlawful possession of a controlled substance, obstruction, and bail jumping, arguing that the Blake ruling invalidated her entire plea agreement. However, the court ruled that while her unlawful possession conviction was vacated, her motions to withdraw her guilty pleas for obstruction and bail jumping were time-barred under RCW 10.73.090.
Background and Procedural History: Guilty Plea and Charges
In 2003, Willyard pleaded guilty to three charges: unlawful possession of a controlled substance, obstruction, and bail jumping. The bail jumping charge arose from her failure to appear at a hearing related to her possession charge. After the 2021 Blake decision, which declared the state’s drug possession law unconstitutional, Willyard moved to withdraw her guilty pleas for all charges, claiming they were part of an indivisible plea agreement.
The trial court vacated her conviction for unlawful possession but denied her motion to withdraw the guilty pleas for obstruction and bail jumping. The Court of Appeals affirmed this decision, stating that the time limit for challenging her other pleas had expired.
Legal Analysis: Time-Barred Under RCW 10.73.090
The Washington Supreme Court ruled that Willyard’s motion to withdraw her guilty pleas was time-barred. According to RCW 10.73.090, a person cannot file a collateral attack on a judgment more than one year after it becomes final, unless certain exceptions apply. While the Blake decision allowed for the vacating of Willyard’s unlawful possession conviction, it did not extend to allow untimely challenges to her guilty pleas for obstruction and bail jumping.
The court emphasized that the Blake ruling was not a material change in law affecting her other guilty pleas, as those convictions were for separate offenses. The court rejected Willyard’s claim that her entire plea agreement should be invalidated due to the vacating of one conviction. The ruling reinforced that subsequent changes in the law do not impact the voluntariness or validity of prior guilty pleas made under then-existing laws.
Conclusion: Guilty Pleas for Obstruction and Bail Jumping Stand
The Washington Supreme Court affirmed the lower courts’ rulings, stating that Nicole Willyard’s guilty pleas for obstruction and bail jumping remain valid and are time-barred from being withdrawn. The court clarified that while the Blake decision impacted her unlawful possession conviction, it did not open the door for untimely challenges to her other guilty pleas. RCW 10.73.090 limits the time period in which these motions can be filed, ensuring that changes in the law, like Blake, only affect related convictions but do not automatically allow for the withdrawal of unrelated pleas.
For more details, read the full opinion here: Washington Supreme Court Opinion – State v. Willyard.
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