State v. Rivers

— Defendant Paul Rivers challenges both his underlying conviction for second degree robbery and the constitutionality of the Persistent Offender Accountability Act, the statute under which he was sentenced to life imprisonment without possibility of parole. We affirm the conviction and the sentence.

Facts

On December 20, 1993, less than three weeks after Washington’s Persistent Offender Accountability Act went into effect, Defendant Paul Rivers was arrested for the robbery of an espresso bar employee in the University District of Seattle.

The victim of the robbery, Josef Slobodzian, testified…