The State of Washington v. Nathaniel R. Broadaway

Summary

The court upheld Broadaway’s conviction and firearm enhancement, concluding that the legislative title of an initiative enacted by the Legislature is the relevant title under article II, section 19, and that the enhancement falls within that title. It also held that confession-voluntariness findings are reviewed under the ordinary substantial-evidence framework and that Broadaway’s confession was voluntary under the totality of the circumstances. The court remanded for resentencing because the judgment and sentence failed to impose the statutorily required one-year community-placement term and the trial court had misstated the required duration. Talmadge, J., concurring, agreed with the disposition but would have required consideration of both the ballot question and legislative title.