# Personal Restraint Petition Of Joseph Leif Wolf

> Court of Appeals of Washington · October 25, 2016 · 196 Wash. App. 496

URL: https://www.frixlaw.com/law-library/cases/9837592

## Case

- **Full name:** In the Matter of the Personal Restraint of Joseph Leif Wolf, Petitioner
- **Court:** Court of Appeals of Washington
- **Decided:** October 25, 2016
- **Citations:** 196 Wash. App. 496; 384 P.3d 591
- **Precedential status:** Published
- **Opinion:** Dissent by Bjorgen
- **Judges:** Maxa, Bjorgen, Johanson
- **Cited by:** 33 later opinions in the Frix Law Library

## Citator (automated)

- No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases.
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/9837592

## How later opinions describe it (automated extraction)

- holding that Wolf’s personal restraint petition (PRP) was time barred because a special sex offender sentencing alternative revocation did not affect the statutory time bar against a PRP, which time started running seven years earlier when the initial sentencing was completed
- holding that Wolf’s personal restraint petition (PRP

## Opinion text

Bjorgen, C. J.
¶45 (dissenting in part) — My dissent in In re Personal Restraint of Dove concluded that under RCW 10.73.100(6), the Supreme Court’s decision in State v. Blazina, 182 Wn.2d 827, 835-37 , 344 P.3d 680 (2015), constituted a “ ‘significant change in the law’ ” that is “ ‘material to the . . . sentence’ ” and that “ ‘sufficient reasons exist to require retroactive application’ ” of the changed law. 196 Wn. App. 148, 166 , 381 P.3d 1280 (2016) (alteration in original) (quoting RCW 10.73.100(6)). For that reason, the Dove dissent would have held that Dove’s challenge to his legal financial obligations (LFOs) was not subject to the one-year time bar for personal restraint petitions (PRPs).
¶46 The same reasoning applies with equal force to Wolf’s PRP. I would hold that his LFO challenge similarly falls within the exception to the PRP time bar of RCW 10.73.100(6) and is properly before us. Therefore, I dissent from the majority’s holding that Wolf’s LFO challenge is barred.
Reconsideration denied November 30, 2016.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/9837592. Public record. Not legal advice.