State Of Washington, V Howard Ernest Sanford

Filed Washington State Court of Appeals Division Two December 8, 2020 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION II STATE OF WASHINGTON, No. 53132-1-II Respondent, v. PUBLISHED OPINION HOWARD ERNEST SANFORD, Appellant. MAXA, J. – Howard Sanford was convicted of first degree rape of a child, first degree child molestation, second degree rape of a child, and second degree child molestation. He argues that the convictions violate double jeopardy principles. We hold that the rape and molestation convictions violate double jeopardy because the trial court did not instruct the jury…