Washington v. Budik
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Petitioner Kenneth Budik was one of two victims of a shooting in Spokane. The other victim, Adama Walton, died as a result of the shooting. Based on Petitioner's statements that he did not know who was responsible for the crime, he was charged with, and convicted of, first degree rendering criminal assistance. Insufficient evidence supported Petitioner's conviction; accordingly, the Supreme Court reversed the Court of Appeals and vacated his conviction. The Court held that in order to prove that a defendant has rendered criminal assistance "by use of . . . deception," the State must show that the defendant made some affirmative act or statement; mere false disavowal of knowledge is insufficient to sustain a conviction for rendering criminal assistance.
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