Summary
The Washington Supreme Court holds that RCW 9A.36.150(1)(b), which criminalizes interfering with the reporting of domestic violence, defines a single crime rather than an alternative means crime. The court affirms Division Three of the Court of Appeals and overturns Division One's contrary holding in State v. Nonog.
Holdings
- RCW 9A.36.150(1)(b) defines a single crime of interfering with the reporting of domestic violence, not three alternative means of committing three separate crimes.
- Buck's conviction did not violate the Washington Constitution's jury-unanimity requirement because the charged offense is a single-means crime.
Questions Presented
- Whether RCW 9A.36.150(1)(b), which criminalizes preventing or attempting to prevent a victim or witness from calling 911, obtaining medical assistance, or making a report to law enforcement, defines one crime or three alternative means of committing the crime.
- Whether Buck's conviction violated the Washington Constitution's right to a unanimous jury verdict.
Disposition
affirmed
Cases Cited (17)
- State v. Buck, 34 Wn. App. 2d 188, 191-94, 567 P.3d 54 (2025)(affirmed)
- State v. Nonog, 145 Wn. App. 802, 811-13, 187 P.3d 335 (2008)(overruled)
- State v. Barboza-Cortes, 194 Wn.2d 639, 643, 650, 451 P.3d 707 (2019)(applied)
- State v. Mayorga DeSantiago, 149 Wn.2d 402, 417, 68 P.3d 1065 (2003)(followed)
- State v. Smith, 159 Wn.2d 778, 784-86, 154 P.3d 873 (2007)(applied)
- State v. Sandholm, 184 Wn.2d 726, 732-35, 364 P.3d 87 (2015)(applied)
- State v. Owens, 180 Wn.2d 90, 95-99, 323 P.3d 1030 (2014)(applied)
- State v. Shoop, 1 Wn.3d 532, 538-39, 543, 528 P.3d 363 (2023)(applied)
- State v. Peterson, 168 Wn.2d 763, 770, 230 P.3d 588 (2010)(applied)
- State v. Arndt, 87 Wn.2d 374, 379, 553 P.2d 1328 (1976)(limited)
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