State Of Washington, V. Samuel Leon Dugan

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE THE STATE OF WASHINGTON, No. 85809-2-I Respondent, v. PUBLISHED OPINION SAMUEL LEON DUGAN, Appellant. BOWMAN, A.C.J. — In September 2023, the trial court sentenced Samuel Leon Dugan to life without the possibility of parole (LWOP) under the Persistent Offender Accountability Act of the Sentencing Reform Act of 1981 (POAA), chapter 9.94A RCW. Dugan appeals, arguing that the POAA’s “three strikes” law is unconstitutional as applied and that the trial court erred by violating his Sixth Amendment1 right to have a jury determine the…