State v. Cham

¶1 Ghe Cham appeals convictions and an exceptional sentence for second degree assault, unlawful *442imprisonment, felony harassment, and misdemeanor violation of a court order. He claims the trial court had an affirmative duty to provide a limiting instruction when it admitted evidence of prior domestic violence under ER 404(b). Alternatively, he argues that his counsel provided ineffective assistance by failing to ask for a limiting instruction. Cham also challenges the sufficiency of the record to demonstrate a valid waiver of his right to a jury trial on one aggravating factor and the…