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Affirms LWOP Sentence for Samuel Dugan Under Three-Strikes Law

The Court of Appeals of Washington, Division One, affirmed Samuel Leon Dugan's life-without-possibility-of-parole (LWOP) sentence under the Persistent Offender Accountability Act (POAA) three-strikes law. Dugan challenged the POAA as unconstitutional as applied, arguing racial disproportionality, and claimed his Sixth Amendment right to jury determination of prior conviction timing was violated. The court rejected both arguments, applying de novo review and presuming the statute constitutional. The trial court's finding that Dugan is a persistent offender with two prior most-serious-offense convictions (second-degree assault in 2002, first-degree burglary in 2005) was upheld.

State v. Dugan - Criminal Appeal

The Washington Court of Appeals, Division I filed an opinion in State v. Dugan on April 20, 2026. The case is an appeal from a King County Superior Court judgment filed September 15, 2023, with Honorable Kenneth L Schubert presiding. The panel consists of Bill Bowman (author), Janet Chung, and Lori Smith.