Washington Law Review


K. D. K.


In March 1969, Sonneland was charged with possession of marijuana, then a felony. His offer to plead guilty to a gross misdemeanor was accepted. Subsequently, a second bargain was made whereby Sonneland agreed to furnish information leading to the arrest of three dealers in exchange for a promise to dismiss all the charges against him. A continuance was granted to provide a cover, and in August 1969, Sonneland gave a tip which culminated in the arrest of three men. It was disputed whether all were dealers. In February 1970, the prosecuting attorney concluded that Sonneland would provide no further information and set the trial date for June 1970. Sonneland moved to dismiss in the interest of justice pursuant to R.C.W. § 10.46.0901 on the ground that he had substantially complied with the bargain. Held: where a defendant substantially complies with a bargain to provide information in exchange for a promise not to prosecute, a dismissal is not an abuse of discretion. State v. Sonneland, 80 Wn. 2d 343, 494 P.2d 469 (1972).

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