State v. Latham

¶1 Dontrail Latham appeals his life sentence, imposed pursuant to the Persistent Offender Accountability Act (POAA).1 Latham argues that he does not qualify as a “persistent offender” because his two Nevada offenses, a guilty plea to battery with “substantial bodily harm” and an Alford2 plea to voluntary manslaughter, are not comparable to Washington State’s “most serious offenses.” Because neither of the two Nevada offenses is comparable to any of Washington State’s most serious offenses raised by the State on appeal or relied on by the trial court, we reverse Latham’s sentence and remand…