State v. Majors
In State v. Majors, 94 Wn.2d 354, 616 P.2d 1237 (1980), the defendant stipulated to two prior convictions for the purpose of being declared a habitual offender in exchange for a reduced charge of second degree murder, even though one of the two prior convictions was for a crime committed after the underlying offense for which he was sentenced as a habitual offender. Majors, 94 Wn.2d at 355-56.
On appeal, the defendant claimed the supplemental information was defective and void on its face because one of his prior felony convictions occurred after the underlying offense for which he was sentenced as a habitual offender. Id.
The Court rejected the defendant's claim and concluded that "inasmuch as defendant's attack . . . was not jurisdictional and he was . . . not misled by the technical defect, we hold he must be held to the terms of the plea bargain." Id. at 359.