State v. Friedlund

¶1 We must determine whether an on-the-record oral ruling may substitute for written findings when a trial court imposes an exceptional sentence — that is, a sentence that is outside the standard sentence range for an offense. We conclude that oral findings do not satisfy the requirements of the Sentencing Reform Act of 1981 (SRA) and remand these matters to the trial court for entry of written findings of fact and conclusions of law (hereinafter written findings). Ch. 9.94A RCW.

¶2 This consolidated appeal consists of two criminal cases. In each case, the jury convicted the defendant and…