State v. Jones

¶1 “ ‘Other than the fact of a prior conviction, any fact that increases the penalty for a crime beyond the prescribed statutory maximum must be submitted to a jury, and proved beyond a reasonable doubt.’ ’,1 Whether one convicted of a crime was on community placement at the time of the offense is a fact that does not fall within the narrow exception of a “prior conviction” for purposes of Blakely v. Washington.2 Because the offender scores of Darrell Jones and Reginald Thomas were improperly based on judicial findings of fact that they were on community placement at the time of their current…