State v. Skillman

After the defendant was found guilty of attempted kidnapping in the second degree, the trial court sentenced him to an exceptional sentence of 36 months in prison, followed by 12 months of community placement. On this appeal, the sole remaining issue is whether the trial court had the authority to require, as a condition of an exceptional sentence, that the defendant serve community placement after his release from prison. Holding that it did not, we reverse.

A trial court's sentencing authority is limited to that expressed in the statutes. In re Carle, 93 Wn.2d 31, 33, 604 P.2d 1293 (1980);…