Washington v. Caton
Annotate this CaseThe Lewis County Superior Court found Defendant Michael Caton guilty of failure to report as a sex offender under the former RCW 9A.44.130 (2008). Defendant appealed, arguing among other things that the evidence did not support his conviction. The Court of Appeals affirmed the conviction. On May 19, 2009, Defendant registered with the Lewis County sheriff's office as a sex offender. On June 9, 2009, he was arrested for a driving offense. On June 10, after Defendant was released from jail, he appeared at the sheriff's office, believing that as a registered sex offender he was required to report to the sheriff after his release from confinement for any offense. But the sheriff's office did not give Defendant a new reporting date, leaving June 16 as the next reporting date. Defendant failed to report on June 16 and instead reported on June 17. The State charged him with failure to register as a sex offender for failing to report in person "on the required day for the 90 day reporting" period. Upon further review, the Supreme Court concluded that the State had not proved that Defendant failed to report within 90 days of his registration: he reported on June 10 and again on June 17, both dates well within 90 days of his registration date of May 19, 2009. Accordingly, the Court reversed Defendant’s conviction.
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