State v. Samuel Dugan
- In June 2020, the trial court convicted Samuel Dugan of first degree promoting prostitution, misdemeanor harassment, third degree assault, and first degree unlawful possession of a firearm. At sentencing, it found that Dugan is a persistent offender and sentenced him to life without the possibility of parole under the Persistent Offender Accountability Act of the Sentencing Reform Act of 1981 (POAA), chapter 9.94A RCW. Dugan appeals, arguing that the POAA’s “three-strikes” law is unconstitutional as applied and that the trial court erred by violating his Sixth Amendment right to have a jury find his prior convictions. Dugan also submits a statement of additional grounds, raising several issues about his underlying convictions. COA # 858092. King County Superior Court # 17-1-06876-1 SEA.