Washington v. Villanueva-Gonzalez (Majority)
Annotate this CaseMiguel Angel Villanueva-Gonzalez was convicted of second degree assault and fourth degree assault for attacking his girl friend. On appeal, he contended that his actions constituted one assault, and therefore two convictions violated double jeopardy. Finding that the legislature has not provided a definition of assault and the common law definition was ambiguous, the Washington Supreme Court was "guided by the many other jurisdictions that have treated assault as a course of conduct crime," and was "mindful of the 'rule of lenity,'" which required the Court to adopt the interpretation most favorable to the defendant. It therefore affirmed the Court of Appeals and held that Villanueva-Gonzalez's two assault convictions violated double jeopardy because the underlying acts occurred during the same course of conduct.
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