''Washout'' Rule In Washington

In re Pers. Restraint of Williams, 111 Wn.2d 353, 356-62, 759 P.2d 436 (1988) applied "wash-out" statute then "in effect" in calculating offender score, i.e., calculating the offender score in a straightforward manner in accord with the directions in the version of RCW 9.94A.360 in effect at the time the defendant committed his offense. In Williams, 111 Wn.2d 353, 759 P.2d 436, the court was faced with the argument that use of the defendant's pre-SRA convictions to determine his offender score under the SRA violated the ex post facto clauses of the state and federal constitutions. Applying the analysis in State v. Randle, 47 Wn. App. 232, 734 P.2d 51 (1987), the Williams court concluded that the SRA does not increase punishment for the defendant's prior offenses, but instead provides for calculation of the sentence for the post-SRA conviction only. Williams, 111 Wn.2d at 363. Therefore, no ex post facto violation occurred.