Opinion
66126-4-I 66127-2-I 66128-1-I
12-19-2011
STATE OF WASHINGTON, Respondent, v. SHANE LEWIS WATSON, Appellant.
UNPUBLISHED OPINION
PER CURIAM.
Shane Watson appeals the jail sanctions imposed following review hearings for violations of his court-ordered financial obligations. He contends the sanctions violate due process because the court did not find that he willfully failed to pay financial obligations for a reason other than his inability to pay. He concedes that he has served the sanctions and that his appeal is moot. He argues, however, that the issue is of sufficient public interest to warrant review.
The State counters that the court conducting the review hearing did not need to make willfulness findings because those findings were made at the earlier sentence violation hearing. It also contends the jail sanctions were properly imposed regardless of Watson's ability to pay because he failed to demonstrate that he made a bona fide effort to obtain employment. See State v. Nason, 168 Wn.2d 936, 945, 233 P.3d 848 (2010) (offender may be imprisoned for failure to pay if he has not made bona fide efforts; burden is on offender to show that his nonpayment is not willful). Watson has not filed a reply to the State's response.
We conclude Watson has not demonstrated grounds for reviewing tlie moot issue raised on appeal. The appeal is therefore dismissed as moot.