Washington v. Hoyt

BRIDGEWATER, J. -- Edward Thomas Hoyt committed a series of third degree thefts, using a common scheme or plan, over a six-month period. The State appeals the trial courts dismissal of five of the six counts that the State had aggregated into felony counts. We hold that RCW 9A.56.010(12)(c) permits a series of third degree thefts pursuant to a common scheme or plan to be aggregated into