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In Re Eduardo Sandoval, WSSC # 92412-1

WACDL filed an amicus brief on Mr. Sandoval's PRP which followed a direct appeal consolidated with a first PRP. This was a successive PRP filed beyond the 1-year time limit which raised different issues. The WSSC granted review on the petition on multiple issues.


Multiple claims of error in a successive PRP including whether error occurred in entering judgment against Mr. Sandoval for crimes with inconsistent mens rea requirements; prosecutorial misconduct; improper denial of a lesser-included instruction for manslaughter; denial of a cautionary instruction on testimony from accomplices; whether Mr. Sandoval was denied his constitutional right to effective legal assistance on appeal; and that Mr. Sandoval's 904 month sentence was unconstitutionally disproportionate in comparison to others convicted from charges arising out of the same event.

WACDL Amicus

In its amicus WACDL addressed the issue of ineffective assistance of counsel on appeal including arguing that the court should take the opportunity to remand for an evidentiary hearing to determine if the current rate and method of compensating appellate counsel contributed to the deficient performance of appellate counsel.


On January 18, 2018 the WSSC issued a ruling in which it found dispositive the issue of failure to instruct on the lesser included offense of Manslaughter and reversed Mr. Sandoval's conviction of first degree murder but let stand his convictions for first degree assault and conspiracy to commit first degree murder. The court found none of the other trial errors raised to be meritorious and declined to address the claims of ineffective assistance of counsel and disproportionate sentence.

WACDL Amicus Author

Suzanne Elliott

Appellate Author

Nathan Rouse, Katharine Tylee

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