Washington v. Murray

Michael Murray appealed his exceptional sentence for three counts of indecent exposure. His appeal raised two questions for the Washington Supreme Court’s review: (1) whether the sexual motivation aggravator, RCW 9.94A.535(3)(f), could apply to the crime of indecent exposure, RCW 9A.88.010; and (2) whether the rapid recidivism aggravator, ROW 9.94A.535(3)(t), was void for vagueness as applied to Murray. The Court held that because indecent exposure lacked an inherent sexual motive, the sexual motivation aggravator could apply. Second, because a reasonable person would not have to guess that reoffending 16 days after being released from jail is "shortly after," the Court held the rapid recidivism aggravator was not void for vagueness as applied to Murray. View "Washington v. Murray" on Justia Law