State v. Gonzales

May a person charged under the first degree escape statute, RCW 9A.76.110(1), challenge the constitutional validity of the convictions which led to confinement? We affirm the judgment of the Court of Appeals and hold that in a prosecution for escape the State is not required to prove the defendant had been detained pursuant to a constitutionally valid conviction.

I

On Saturday, April 3, 1982, Robert B. Gonzales was detained at the Tri-State Work Release Facility pursuant to prior burglary convictions. At about 6:45 that morning, Gonzales signed out of the facility, telling the authorities that…