State v. Rangel

Frank Rangel appeals his nonjury convictions of two counts of second degree burglary. The burglaries occurred in September 1980 and February 1981, the first of a residence, the second of a business.

Mr. Rangel raises the following issue: Were the requirements of CrR 6.1(a) regarding waiver of jury trial met here? That rule provides: "Trial by Jury. Cases required to be tried by jury shall be so tried unless the defendant files a written waiver of a jury trial, and has consent of the court." No written waiver was filed, but the following colloquy occurred prior to trial:

The Court: Before we…