In the Matter of the Personal Restraint of Jeffrey A. Coats

Summary

The Washington Supreme Court denied Jeffrey Coats's untimely personal restraint petition challenging his 1995 guilty-plea convictions. The court held that his judgment and sentence, though it erroneously stated a life maximum for conspiracy to commit first degree robbery (actual maximum 10 years), was valid on its face because the sentencing court did not exceed its statutory authority, so the petition was time barred under RCW 10.73.090. The court announced that only errors where the court actually exceeds its authority render a judgment and sentence facially invalid, and that the facial-invalidity exception may not be used as a gateway to circumvent the one-year time bar for other claims. It remanded to the trial court to correct the clerical error under CrR 7.8(a). Chief Justice Madsen concurred separately, urging a strict plain-language reading of 'valid on its face'; Justice Stephens, joined by Justice Fairhurst, concurred separately, agreeing the judgment was facially invalid but finding no prejudice and dismissing the guilty-plea claim as untimely.