State v. Snyder

In State v. Snyder, 40 Wn. App. 338, 698 P.2d 597, 597 (Wash. App. 1985) the defendant pled guilty to second degree escape based on his unauthorized absence while being detained for burglary. The defendant subsequently escaped again. Id. After being recaptured, he was convicted of first degree escape. Id. The defendant argued the State failed to prove he was being detained pursuant to a felony because the State "failed to show that at the time of his absence he had been serving a sentence for" the felony. 698 P.2d at 598. The court held that a defendant "need not be serving time on the underlying conviction in order to be 'detained pursuant to a conviction of a felony.'" Id.