State v. Riggins

Defendant appeals his convictions for burglary and theft. At sentencing, he challenged the use of two juvenile adjudications in determining his criminal history score, arguing that those adjudications were constitutionally defective because they were uncounseled. The sentencing court rejected defendant’s challenge and calculated defendant’s criminal history score using the juvenile adjudications. Defendant challenges that ruling on appeal. We agree that use of the juvenile adjudications was error, and we remand for resentencing.

Defendant’s two prior juvenile adjudications arose from a single…