State v. Dunaway

Durham, J. —

These three cases involve interpretation of the Sentencing Reform Act of 1981 (SRA) relating to the calculation of a defendant's standard sentence range. One of the factors in that calculation is the defendant's offender score, which measures the length and severity of his criminal history. The SRA, RCW 9.94A, provides that separate crimes encompassing "the same criminal conduct" must be treated as one crime in determining criminal history. RCW 9.94A.400(l)(a). The cases currently before this court present a variety of factual settings to which this statute must be applied. In…