State v. Winborne

¶1 Changes to the Sentencing Reform Act of 1981 (SRA)1 require that we revisit how sentencing courts address terms of community custody in entering an offender’s judgment and sentence to ensure that the sentence does not exceed the statutory maximum for the crime. Amendments effective in 2009 no longer enable a sentencing court to make the form of judgment notation approved in In re Personal Restraint of Brooks, 166 Wn.2d 664, 675, 211 P.3d 1023 (2009) — directing the Department of Corrections to release an offender from community custody before the date that would exceed the statutory…