Washington v. Donaghe
Annotate this CaseDefendant Samuel Donaghe was convicted of second degree rape. In 1995, when Defendant’s incarceration was set to end, the State filed a petition to have Defendant committed as a “sexually violent predator” (SVP). In 2000 while awaiting his for his SVP commitment trial, Defendant moved to obtain a certificate of discharge for his rape convictions. The State argued against the discharge because Defendant had not fulfilled his community placement sentence, which the State argued tolled while he was confined. The trial court agreed with the State and denied Defendant’s motion. Three years later in 2003, the court found Defendant as an SVP. The Court of Appeals affirmed that determination in 2005. In 2007, Defendant renewed his motion for a certificate of discharge, but the trial court adhered to its 2000 ruling, holding that defendant’s custodial detention tolled the running of the community placement requirement. Defendant moved for reconsideration. The appeals court held that because Defendant had been detained as an SVP, his term of community placement could not “begin” until the State released him to the supervision of the community. Therefore, his sentence was not complete, and he was not entitled to a certificate of discharge. Upon review, the Supreme Court affirmed the Court of Appeals. The Court held that the trial court had the authority to deny Defendant’s certificate of discharge because his community placement was indeed tolled by his confinement as an SVP.
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