Knight and her co-conspirators planned to rob Arren Cole. Knight lured Cole into an alley where one of her co-conspirators robbed and shot Cole. Cole was rushed to the hospital but pronounced dead on arrival. The state of Washington charged Knight with conspiracy to commit second degree robbery, conspiracy to commit first degree burglary, conspiracy to commit first degree robbery, attempted first degree robbery, and first degree murder. Knight negotiated a plea in which she was to testify against her co-conspirators, forfeit her car, and plead guilty to conspiracy to commit second degree robbery, conspiracy to commit first degree burglary, and second degree murder. The court accepted her pleas, reduced them to judgment, and sentenced her to twenty-four years in prison. Knight appealed the court's sentencing claiming that two of the charges were violated the double jeopardy clause. She argued that the conspiracy to commit first degree burglary and the conspiracy to commit second degree robbery are multiple convictions for a single “unit of prosecution.” The Court of Appeals agreed with Knight’s argument and reversed her conviction of conspiracy to commit first degree burglary. The state of Washington petitioned for review arguing the charges were not in violation of the double jeopardy clause. It also claimed that reversing one conviction in a plea agreement was improper without rejecting the whole plea agreement. Washington’s Constitution has the same interpretation of the Fifth Amendment with the addition of a protection for defendants in which it “protects against multiple punishments for the same offense.” With this being said, Knight was right in arguing her conviction was unconstitutional.
The court’s findings about the violation of double jeopardy was just. The Court of Appeals determined Knight’s two convictions punished her twice for one conspiracy which is a violation of the double jeopardy clause. Knight’s guilty plea did waive some constitutional protection pertaining to factual guilt, it did not whatsoever waive any protection against double jeopardy.
This is a very intriguing case, as Knight took a plea deal but happened to be charged “multiple convictions for a single ‘unit of prosecution’.” What makes this case especially interesting is that Oregon specifically spells out in its Constitution that along with the similar language of the 5th Amendment the Constitution states “protects against multiple punishments for the same offense.” Due to this addition to Oregon’s constitution, I agree with the Appeals Court ruling that Knight’s conviction was unconstitutional. I really like the addition to Oregon’s constitution about preventing someone against multiple punishments for the same offense.
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