Washington v. Owens (Majority)
Annotate this CaseRespondent Jeramie Owens and a friend visited a car dealership in Mount Vernon after seeing a 1967 Volkswagen (VW) Beetle with a high performance engine, roof rack and surfboard on top. They took the car on a test ride but left without purchasing the car or leaving their names. The next day, a salesman opened the dealership and discovered that the same 1967 VW Beetle that respondent test drove the day before had been stolen, and one of the dealer's keys was missing. The next business day, respondent registered a 1971 VW Beetle, the registration for which had expired in 1993. In response to a listing on Craig's List, Craig Sauvageau purchased the 1971 Beetle from respondent. Claiming that he had lost the title respondent provided Sauvageau an affidavit in lieu of title. Savageau took the car to his mechanic to have it inspected, and the mechanic discovered that the VIN registered by respondent a few days prior appeared to be brand new with reinstalled rivets. Savageau called police to report the car as potentially stolen. Police discovered the confidential VIN matched that of the stolen 1967 VW from the dealership. Respondent would later be charged with first degree taking a motor vehicle without permission, first degree trafficking in stolen property, possession of a stolen vehicle and bail jumping. A jury convicted respondent on all charges but taking a motor vehicle without permission. The issue this case presented for the Supreme Court's review involved whether whether RCW 9A.82.050(1) described alternative means of committing first degree trafficking in stolen property, and if so, whether substantial evidence supported each of the alternative means in this case. The Court of Appeals held that RCW 9A.82.050 described eight alternative means of committing the crime, and because there was insufficient evidence to support at least one of those eight means, the court reversed respondent's conviction. The Supreme Court reversed the Court of Appeals, reinstated the conviction, and held that RCW 9A.82.050 described only two alternative means, and in this case, each was supported by sufficient evidence.
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