State v. McRae
In State v. McRae, 96 Wn. App. 298, 979 P.2d 911 (1999), review denied, 139 Wn.2d 1021, 994 P.2d 849 (2000), the Court of Appeals rejected the argument that a defendant has a substantive right stemming from prior sentencing laws referenced in a plea agreement.
The court reasoned that a plea agreement does not entitle a defendant to any exemption from the sentencing laws, where the agreement accurately informs the offender of the current law respecting sentencing.
The court also noted that the State's obligation is to act in good faith and not contravene any reasonable expectations of the defendant that arise from the agreement. McRae, 96 Wn. App. at 305.
The court said that a defendant does not have any reasonable expectation that the sentencing laws will not change. Id.