State v. Lee

The trial court held that offenses which are part of a common plan are subject to the mandatory joinder rule of former CrR 4.3(c) and dismissed the charges in this case because they were not joined with those prosecuted in State v. Lee, 128 Wn.2d 151, 904 P.2d 1143 (1995) (Lee I). The Court of Appeals affirmed on different grounds, essentially finding that the purpose of the mandatory joinder rule would be satisfied only if joinder is required. We reverse and remand this case for trial.

FACTS

Defendant and his associate advertised in a local newspaper that they had houses for rent. The facts…