Washington v. Johnson (Majority, Concurrence and Dissent)
Annotate this CaseRespondent-cross-petitioner J.C. Johnson was convicted of five crimes related to several days of ongoing domestic violence against his wife. A jury convicted Johnson for holding his wife “J.J.” under his control, allowing her only to leave their apartment when Johnson left, using his Rottweiler to restrain her movements, and keeping a knife and icepick near the bed to intimidate her. For three days, Johnson severely injured his wife by choking her, hitting her with rocks, and allowing the dog to bite her. J.J. managed to escape and receive treatment for her injuries. On appeal, Johnson argued: (1) the information for the unlawful imprisonment charges were insufficient because it did not include a definition of the word “restraint;” and (2) he received ineffective assistance of counsel when his trial lawyer proposed a definition of “reckless” in jury instructions that did not include charge-specific language when the “to convict” instruction included the specific language. The Court of Appeals overturned Johnson’s unlawful imprisonment conviction because the State omitted the definition of “restrain.” The appellate court agreed with Johnson that it was error to give a jury instruction on a generic definition of “reckless,” but that trial counsel was not ineffective for proposing it. The Supreme Court reversed on the “restraint” issue, holding that charging documents need only contain essential elements of a crime, not related definitions. With regard to the “reckless” issue, the Supreme Court affirmed the Court of Appeals, but for a different reason: it was not error to instruct a jury on the generic definition as long as the jury was given a “to convict” instruction that lists every element of the crime the State needs to prove in order to convict the defendant.
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