In the Matter of the Personal Restraint of Amel W. Dalluge

Summary

The Washington Supreme Court considered whether the Department of Corrections retained authority to enforce community-custody conditions and sanction an offender for misconduct committed while the offender was confined in jail. The court held that tolling the period of community custody during confinement did not suspend the department's supervisory authority or the offender's obligation to comply with custody conditions. The court affirmed dismissal of Amel Dalluge's personal restraint petition.

Holdings

1. Tolling the period of community custody during an offender's confinement does not toll the Department of Corrections' supervisory authority or its ability to enforce community-custody conditions. The Department therefore had statutory authority to sanction Dalluge for jailhouse misconduct that violated those conditions.
2. The court denied the Department's motion to dismiss as moot because the issue presented a continuing and substantial public interest, guidance would assist public officers, and the issue was likely to recur.
3. The court declined to disturb dismissal of Dalluge's equal-protection and notice claims because he supported neither claim with argument or citation and appeared to have abandoned them.

Questions Presented

1. Whether the Department of Corrections retained statutory authority to enforce community-custody conditions and sanction an offender for misconduct committed while the offender was confined in jail and the period of community custody was tolled.
2. Whether the personal restraint petition was moot.
3. Whether the dismissal of Dalluge's unsupported equal-protection and notice claims should be disturbed.

Disposition

affirmed