State v. Williams
Washington Supreme Court
158 Wash. 2d 904, 148 P.3d 993 (2006)
- Written by Miller Jozwiak, JD
Facts
Matthew Williams (defendant) was cleaning out his grandmother’s home when he found his deceased grandfather’s shotgun. To protect others from injury, Williams locked the shotgun in a bathroom. A few days later, a deputy sheriff was searching for a juvenile suspect. Williams told the deputy that the juvenile was not in his grandmother’s home. Williams then allowed the deputy to search the house for the suspect. When Williams unlocked the door, the deputy saw the shotgun sitting on top of the toilet. The deputy noticed that the length of the shotgun’s barrel was shorter than allowed by state law. Specifically, the shotgun’s barrel was five inches shorter than the length allowed by law. The deputy arrested Williams, and the state (plaintiff) charged him with one count of unlawful firearm possession. At trial, the jury instructions stated that Williams had to knowingly possess a short-barreled shotgun. The jury convicted Williams, who appealed. Williams claimed that the instruction was erroneous because the state had to establish that he knew the barrel length was too short. The state argued that it had to establish merely that Williams knew he possessed the firearm, regardless of length.
Rule of Law
Issue
Holding and Reasoning (Madsen, J.)
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