Following the 1989 session of the Washington Legislature, the Indeterminate Sentence Review Board (Board) began redetermining the minimum terms of prisoners serving a mandatory life sentence for crimes committed before July 1984. To calculate these new minimum terms, the legislature directed the Board to apply the same sentencing ranges enacted in the Washington Sentencing Reform Act, which took effect July 1, 1984. This Comment analyzes whether the state violated the United States Constitution when it ordered that these minimum terms be redetermined. It concludes that Washington courts should void the state's action because it violates the constitutional prohibition against ex post facto laws.
Steven J. Samario,
Applying Washington's Sentencing Reform Act to Mandatory Life Prisoners: An Ex Post Facto Violation,
66 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol66/iss1/7