Waiver of Right to Appeal As Part of a Plea Bargain In Washington

In State v. Majors, 94 Wn.2d 354, 356-57, 616 P.2d 1237 (1980), a defendant who had been charged with first degree murder entered into an agreement in which he pleaded guilty to a reduced charge of second degree murder and to being a habitual criminal. 94 Wn.2d at 355. As part of the bargain, Majors explicitly waived his right to appeal. Id. Later, however, on appeal Majors argued that the supplemental information was defective and void because one of his prior felony convictions occurred after the underlying offense for which he was sentenced as a habitual criminal. Majors, 94 Wn.2d at 355-56. The Majors court rejected his claim: "Inasmuch as petitioner's attack on the supplemental information was not jurisdictional and petitioner was concededly not misled by the technical defect, we hold he must be held to the terms of the plea bargain." Majors, 94 Wn.2d at 359.