State v. Tyler (Majority and Concurrence)
Annotate this CaseRobert Tyler challenged his conviction for possessing a stolen vehicle. He contended the State was required to prove he engaged in all the actions that constitute "possession" of a stolen vehicle because these were listed in the to-convict jury instruction. Further arguing that the evidence is insufficient to prove he "disposed of a stolen vehicle, Tyler contended his conviction had to be reversed and the case dismissed with prejudice. The Washington Supreme Court affirmed Tyler's conviction, although on different grounds than those relied on by the Court of Appeals, which viewed the jury instructions as setting alternative means of possessing stolen property, which became the “law of the case” under Washington v. Hickman, 954 P.2d 900 (1998). The appellate court held Hickman was abrogated by Musacchio v. United States, 136 S.Ct. 709 (2016). The Washington Supreme Court determined that was error in light of the Washington Court’s decision in Washington v. Johnson, 399 P.3d 507 (2017). In Johnson, the Washington Court confirmed Hickman remained good law. Because it was undisputed that the evidence established possession, the jury's verdict stood, and the Court affirmed Tyler's conviction.
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