State v. Nonog

Summary

The Washington Supreme Court held that an information charging interference with domestic violence reporting was constitutionally sufficient. Reading the multicount information as a whole, the court concluded that the defendant was reasonably apprised that the underlying domestic violence offenses were those charged in other counts occurring on the same date.

Holdings

1. The information was constitutionally sufficient because, when liberally construed as a whole, it reasonably apprised Nonog that the underlying domestic violence offenses referenced in the interference count were the domestic violence crimes charged in counts I and II.
2. Nothing in the liberal-construction standard requires each count to be read in isolation when determining whether the information reasonably apprised the accused of the charged offense.

Questions Presented

1. Whether the information was constitutionally sufficient when the count charging interfering with domestic violence reporting did not specify the underlying domestic violence crime.
2. Whether, under the liberal-construction rule, the court could consider the information as a whole, including other counts charging domestic violence offenses occurring on the same date, to determine whether the defendant received constitutionally adequate notice.

Disposition

affirmed