State v. Heath

¶1 — Is a “nolo contendere” plea followed by a “withheld adjudication” of guilt in Florida a “conviction” under Washington law for sentencing purposes? We answer yes and affirm.

¶2 Raymond Heath was convicted of second degree assault and fourth degree assault. The parties disagreed *896about whether Heath’s two Florida offenses counted as prior convictions for the purpose of determining his offender score at sentencing.

¶3 Heath was charged in Florida with two counts of possession of cocaine in two different incidents in 2002. For each charge, Heath entered a plea of nolo contendere, or no contest.…