State v. Brown

¶1 After a trial conducted partially in absentia, a jury found Johnnie Gerard Brown guilty of child rape and incest. Nine years later, authorities apprehended Brown, who had absconded to another state, and returned him to Washington for sentencing. The sentencing court declined to order a presentence report before imposing the maximum standard-range term of incarceration. Brown appeals, arguing (1) that the trial court improperly tried him in absentia in violation of his right under CrR 3.4 to be present at all stages of trial and (2) that the sentencing court committed reversible error when…