State of Washington, Respondent v. David Angel Ramirez, Petitioner.

Summary

The Washington Supreme Court held that a trial court's compliance with the Blazina requirement of an individualized, on-the-record inquiry into a defendant's current and future ability to pay discretionary legal financial obligations (LFOs) is reviewed de novo, and that the trial court here failed to conduct an adequate inquiry because it asked only two questions—both directed to the State—and never explored Ramirez's debts, GR 34 indigency status, or financial circumstances. The court further held that House Bill 1783, enacted while Ramirez's appeal was pending, applies prospectively to his case and prohibits imposition of the $2,100 in discretionary LFOs and the $200 criminal filing fee on him as an indigent defendant. The court reversed the Court of Appeals and remanded for the trial court to strike those amounts from the judgment and sentence without a resentencing hearing.