Grohs v. State

In Grohs v. State, 118 P.3d 1080 (Alaska App. 2005) the Court directly addressed aggravator (c)(21) (criminal history of similar conduct). The Court held that, at least when a defendant did not dispute the existence of the prior convictions, "and when the State relied simply on the convictions themselves and the legal elements of those crimes, rather than attempting to introduce evidence of the particular facts underlying the prior convictions" the court could find the aggravator without violating Blakely v. Washington.