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State v. Blake

Washington Supreme Court

481 P.3d 521 (2021)

Facts

Shannon Blake (defendant) was present at a property that was subject to a police search pursuant to a warrant. Consequently, Blake was arrested. While Blake was in custody at the jail, an officer found a small bag of methamphetamine in the pocket of Blake’s jeans. The State of Washington (plaintiff) charged Blake with possession of a controlled substance, which was a strict liability crime. Blake invoked the unwitting-possession affirmative defense at trial. Blake testified that her friend gave her the jeans two days before the arrest, that she did not know drugs were in her pocket, and that she never used methamphetamine. Blake’s boyfriend corroborated Blake’s testimony. The trial court found that Blake had possessed methamphetamine, but it did not find that the state had proved that Blake intended to possess the drugs or knew that she possessed the drugs. The trial court also indicated that Blake had not proved unwitting possession. The trial court found Blake guilty of possession of a controlled substance. Blake appealed, arguing that requiring her to prove unwitting possession violated her due-process rights. The court of appeals affirmed the trial court’s decision. Blake appealed.

Rule of Law

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Issue

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Holding and Reasoning (McCloud, J.)

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A "yes" or "no" answer to the question framed in the issue section;
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The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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