mens rea requirement (Washington) · Go Syfert
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mens rea requirement in Washington

40 Washington opinions name it 2 courts 1960–2026 11 in the last five years

The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (13)

CaseFollowedCited
State v. Williamsgreen
wash · 2006 · cited in 2 Washington opinions naming this issue, 2021–2024
2 sentences

2024See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 Wn.2d 357 , 360- 11 57910-3-II 67, 5 P.3d 1247 (2000) (same for RCW 9.41.040).

2021See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 9 Significantly, Moreno does not show that he was unable to argue his theory that he was in the townhome lawfully, and the jury was provided with the instructions that mirrored the language of the statute for unlawfully entering or remaining. 15 State v. Moreno, No. 99147- 2 Wn.2d 357, 360-67 , 5 P.3d 1247 (2000) (same for RCW 9.41.040)).

22
State v. Williamsgreen
wash · 2006 · cited in 2 Washington opinions naming this issue, 2021–2024
2 sentences

2024See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 Wn.2d 357 , 360- 11 57910-3-II 67, 5 P.3d 1247 (2000) (same for RCW 9.41.040).

2021See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 9 Significantly, Moreno does not show that he was unable to argue his theory that he was in the townhome lawfully, and the jury was provided with the instructions that mirrored the language of the statute for unlawfully entering or remaining. 15 State v. Moreno, No. 99147- 2 Wn.2d 357, 360-67 , 5 P.3d 1247 (2000) (same for RCW 9.41.040)).

22
United States v. Ulibarrigreen
nmd · 2015 · cited in 2 Washington opinions naming this issue, 2016–2016
2 sentences

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

2016See United States v. Rapert, 75 M.J. 164 , 168 12 No. 92593-3 (C.A.A.F. 2016) (because "the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated" in the provision in question, this "places the case at bar beyond the reach of Elonis"); United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) ("Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. ... [Accordingly, b]ecause [the provision in question] already 'separate[s] wrongful conduct from otherwise innocent conduct,' Elonis v. United States, 135 S.Ct.

22
State v. Goregreen
wash · 1984 · cited in 2 Washington opinions naming this issue, 2016–2016
2 sentences

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

22
United States v. Rapertgreen
armfor · 2016 · cited in 2 Washington opinions naming this issue, 2016–2016
2 sentences

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

2016See United States v. Rapert, 75 M.J. 164 , 168 12 No. 92593-3 (C.A.A.F. 2016) (because "the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated" in the provision in question, this "places the case at bar beyond the reach of Elonis"); United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) ("Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. ... [Accordingly, b]ecause [the provision in question] already 'separate[s] wrongful conduct from otherwise innocent conduct,' Elonis v. United States, 135 S.Ct.

22
People v. Murillogreen
calctapp · 2015 · cited in 2 Washington opinions naming this issue, 2016–2016
2 sentences

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

2016See United States v. Rapert, 75 M.J. 164, 168 (C.A.A.F. 2016) (because “the infirmities found in 18 U.S.C. § 875 (c) [i.e., absence of mens rea] are not replicated” in the provision in question, this “places the case at bar beyond the reach of Elonis”)-, United States v. Ulibarri, 115 F. Supp. 3d 1308, 1333 (D.N.M. 2015) (“Unlike [18 U.S.C.] § 875(c), [the provision in question] already contains a mens rea requirement. . . . [Accordingly, b]ecause [the provision in question] already ‘separate [s] wrongful conduct from otherwise innocent conduct,’ Elonis v. United States, 135 S. Ct. at 2011 , a

22
Bianco v. California Highway Patrolgreen
calctapp · 1994 · cited in 2 Washington opinions naming this issue, 1998–1998
2 sentences

1998See Bianco, 24 Cal. App. 4th 1113 . 7 The State correctly contends that the issue for due process is adequate notice, that is, fair warning of what is prohibited.

1998See Bianco, 24 Cal.App.4th 1113 , 29 Cal.Rptr.2d 711 . [7] *358 The State correctly contends that the issue for due process is adequate notice, that is, fair warning of what is prohibited.

22
Elonis v. United Statesgreen
scotus · 2015 · cited in 4 Washington opinions naming this issue, 2016–2021
2 sentences

2021Thus, the statute does not criminalize “idle talk” or “political argument.” We agree this statute implies a mens rea requirement above negligence and is therefore consistent with “‘the conventional requirement for criminal conduct—awareness of some wrongdoing.’” Elonis, 135 S. Ct. at 2011 (quoting Staples v. United States, 511 U.S. 600, 606-07 , 114 S. Ct. 1793 , 128 L.

2021Thus, the statute does not criminalize “idle talk” or “political argument.” We agree this statute implies a mens rea requirement above negligence and is therefore consistent with “‘the conventional requirement for criminal conduct—awareness of some wrongdoing.’” Elonis, 135 S. Ct. at 2011 (quoting Staples v. United States, 511 U.S. 600, 606-07 , 114 S. Ct. 1793 , 128 L.

14
Leocal v. Ashcroftgreen
scotus · 2004 · cited in 1 Washington opinions naming this issue, 2026–2026
2 sentences

2026It added that because the Supreme Court previously held that a DUI “cannot be considered a crime of violence because it lacked a mens rea requirement,” a “DUI cannot be categorically defined as a crime of violence for which there may be historical support for Second Amendment restrictions.” Id. (citing Leocal v. Ashcroft, 543 U.S. 1, 4, 125 S. Ct. 377, 160 L.

2026It added that because the Supreme Court previously held that a DUI “cannot be considered a crime of violence because it lacked a mens rea requirement,” a “DUI cannot be categorically defined as a crime of violence for which there may be historical support for Second Amendment restrictions.” Id. (citing Leocal v. Ashcroft, 543 U.S. 1, 4, 125 S. Ct. 377, 160 L.

11
State v. Contegreen
wash · 2007 · cited in 1 Washington opinions naming this issue, 2020–2020
2 sentences

2020Conte, 159 Wn.2d at 811 (“Further, as the State maintains, RCW 40.16.030 contains a mens rea requirement.

2020Conte, 159 Wn.2d at 811 (“Further, as the State maintains, RCW 40.16.030 contains a mens rea requirement.

11
State v. Clarkgreen
washctapp · 2013 · cited in 1 Washington opinions naming this issue, 2020–2020
1 sentence

2020See Clark, 175 Wn.

11
State v. Bauergreen
wash · 1979 · cited in 1 Washington opinions naming this issue, 2017–2017
11
State v. Hallgreen
wash · 1985 · cited in 1 Washington opinions naming this issue, 2017–2017
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (30)

CaseCitedYears
Staples v. United States green
scotus · 1994
2 sentences

2021Thus, the statute does not criminalize “idle talk” or “political argument.” We agree this statute implies a mens rea requirement above negligence and is therefore consistent with “‘the conventional requirement for criminal conduct—awareness of some wrongdoing.’” Elonis, 135 S. Ct. at 2011 (quoting Staples v. United States, 511 U.S. 600, 606-07 , 114 S. Ct. 1793 , 128 L.

2021Thus, the statute does not criminalize “idle talk” or “political argument.” We agree this statute implies a mens rea requirement above negligence and is therefore consistent with “‘the conventional requirement for criminal conduct—awareness of some wrongdoing.’” Elonis, 135 S. Ct. at 2011 (quoting Staples v. United States, 511 U.S. 600, 606-07 , 114 S. Ct. 1793 , 128 L.

42019–2021
United States v. United States Gypsum Co. green
scotus · 1978
2 sentences

2016Ed. 2d 608 (1994) (“ ‘ [t] he existence of a mens rea is the rule of, rather than the exception to, the principles of Anglo-American criminal jurisprudence’ ” (alteration in original) (quoting United States v. U.S. Gypsum Co., 438 U.S. 422, 436 , 98 S. Ct. 2864 , 57 L.

2016Ed. 2d 608 (1994) (“ ‘ [t] he existence of a mens rea is the rule of, rather than the exception to, the principles of Anglo-American criminal jurisprudence’ ” (alteration in original) (quoting United States v. U.S. Gypsum Co., 438 U.S. 422, 436 , 98 S. Ct. 2864 , 57 L.

32016–2019
City of Seattle v. Webster green
wash · 1990
2 sentences

2014App. 951, 960-61 , 231 P.3d 212 (2010), Division One relied on the mens rea requirement imposed by the statute, likening it to the pedestrian interference ordinance that our Supreme Court concluded was not overbroad in City of Seattle v. Webster, 115 Wn.2d 635 , 802 P.2d 1333 (1990).

2014App. 951, 960-61 , 231 P.3d 212 (2010), Division One relied on the mens rea requirement imposed by the statute, likening it to the pedestrian interference ordinance that our Supreme Court concluded was not overbroad in City of Seattle v. Webster, 115 Wn.2d 635 , 802 P.2d 1333 (1990).

32013–2014
State v. Coleman neutral
washctapp · 2010
2 sentences

2014App. 951, 960-61 , 231 P.3d 212 (2010), Division One relied on the mens rea requirement imposed by the statute, likening it to the pedestrian interference ordinance that our Supreme Court concluded was not overbroad in City of Seattle v. Webster, 115 Wn.2d 635 , 802 P.2d 1333 (1990).

2014App. 951, 960-61 , 231 P.3d 212 (2010), Division One relied on the mens rea requirement imposed by the statute, likening it to the pedestrian interference ordinance that our Supreme Court concluded was not overbroad in City of Seattle v. Webster, 115 Wn.2d 635 , 802 P.2d 1333 (1990).

32013–2014
State v. Ferguson procedural
washctapp · 2011
2 sentences

2014In State v. Ferguson, 164 Wn.

2014In State v. Ferguson, 164 Wn.

32013–2014
State v. Anderson green
wash · 2000
2 sentences

2024See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 Wn.2d 357 , 360- 11 57910-3-II 67, 5 P.3d 1247 (2000) (same for RCW 9.41.040).

2021See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 9 Significantly, Moreno does not show that he was unable to argue his theory that he was in the townhome lawfully, and the jury was provided with the instructions that mirrored the language of the statute for unlawfully entering or remaining. 15 State v. Moreno, No. 99147- 2 Wn.2d 357, 360-67 , 5 P.3d 1247 (2000) (same for RCW 9.41.040)).

22021–2024
State v. Blake green
wash · 2021
2 sentences

2021State v. Blake, 197 Wn.2d 170, 195 , 481 P.3d 521 (2021).

2021State v. Blake, 197 Wn.2d 170, 195 , 481 P.3d 521 (2021).

22021–2021
State v. Roberts green
wash · 2000
2 sentences

2018"The language of the accomplice liability statute establishes a mens rea requirement of'knowledge' of 'the crime.'" Roberts, 142 Wn.2d at 510 (quoting RCW 9A.08.020(3)(a)).

2002The statute, which is based on section 2.06(3) of the Model Penal Code, “establishes a mens rea requirement of ‘knowledge’ of ‘the crime.’ ” Roberts, 142 Wn.2d at 510 .

22002–2018
State v. Danforth green
wash · 1982
2 sentences

2017Mr. Buttolph relied principally on State v. Danforth, 97 Wn.2d 255 , 643 P.2d 882 (1982) for the proposition that the legislature plainly intended to impose a greater mens rea requirement for this statute.

2017Mr. Buttolph relied principally on State v. Danforth, 97 Wn.2d 255 , 643 P.2d 882 (1982) for the proposition that the legislature plainly intended to impose a greater mens rea requirement for this statute.

22017–2017
State v. Smith green
wash · 1980
2 sentences

2015Our Supreme Court rejected a similar argument in State v. Smith, 93 Wn.2d 329, 345 , 610 P.2d 869 (1980).

2015Our Supreme Court rejected a similar argument in State v. Smith, 93 Wn.2d 329, 345 , 610 P.2d 869 (1980).

22015–2015
State v. Chhom green
wash · 1996
2 sentences

2010Although the State is correct that rape of a child is a strict liability crime, see State v. Chhom, 128 Wash.2d 739, 743 , 911 P.2d 1014 (1996), the "minimal mental element" of volition—as part of the actus reus—must be proved even for those crimes without a mens rea requirement.

2010Although the State is correct that rape of a child is a strict liability crime, see State v. Chhom, 128 Wash.2d 739, 743 , 911 P.2d 1014 (1996), the "minimal mental element" of volition—as part of the actus reus—must be proved even for those crimes without a mens rea requirement.

22010–2010
Cornwall v. State green
alaskactapp · 1996
2 sentences

2008Cornwall, 915 P.2d at 648-49 .

2008Cornwall, 915 P.2d at 648-49 .

22008–2008
Counterman v. Colorado green
scotus · 2023
2 sentences

2024Counterman v. Colorado, 600 U.S. 66, 69 , 143 S. Ct. 2106 , 216 L.

2024Counterman, 600 U.S. at 75 .

12024–2024
State v. Anderson green
wash · 2000
1 sentence

2024See, e.g., State v. Williams, 158 Wn.2d 904, 908-16 , 148 P.3d 993 (2006) (reading in a mens rea requirement to unlawful possession of a firearm pursuant to RCW 9.41.190(1)); State v. Anderson, 141 Wn.2d 357 , 360- 11 57910-3-II 67, 5 P.3d 1247 (2000) (same for RCW 9.41.040).

12024–2024
State Of Washington v. Docie Burch green
washctapp · 2016
1 sentence

2024State v. Burch, 197 Wn.

12024–2024
State Of Washington, V. Turner Lee Calloway green
washctapp · 2024
1 sentence

2024Id.

12024–2024
Dunner v. McLaughlin green
wash · 1984
1 sentence

2024Id.

12024–2024
State v. Cleppe green
wash · 1981
2 sentences

2021We reiterated this principle in State v. Cleppe, 96 Wn.2d 373, 378 , 635 P.2d 435 (1981), unanimously rejecting a challenge to the validity of the legislature’s power to enact RCW 69.50.401(c), which continued to make possession of a controlled substance a crime without a mens rea requirement.

2021We reiterated this principle in State v. Cleppe, 96 Wn.2d 373, 378 , 635 P.2d 435 (1981), unanimously rejecting a challenge to the validity of the legislature’s power to enact RCW 69.50.401(c), which continued to make possession of a controlled substance a crime without a mens rea requirement.

12021–2021
State v. WEAVILLE green
washctapp · 2011
1 sentence

2019Weaville, 162 Wn.

12019–2019
State v. Maxfield green
wash · 1994
12017–2017
State v. Kilburn green
wash · 2004
12017–2017
Bishop v. City of Spokane green
washctapp · 2007
12017–2017
Verda Lee Crosswhite Vv Washington State Dept. of Social & Health Services green
washctapp · 2017
12017–2017
State v. Bash green
wash · 1996
12016–2016
Brandenburg v. Ohio green
scotus · 1969
12015–2015
State v. Gamble green
wash · 2005
12011–2011
State v. Ware neutral
washctapp · 2002
12007–2007
State v. Ware green
washctapp · 2002
12007–2007
State v. Roberts green
wash · 2001
12002–2002
Dennis v. United States green
scotus · 1951
11960–1960

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (12) WA § Wash. Rev. Code § 9A.08.010 (8) WA § Wash. Rev. Code § 9A.46.020 (8) WA § Wash. Rev. Code § 69.50.4013 (6) WA § Wash. Rev. Code § 9A.08.020 (6) USC § 18u.s.c.875 (5) WA § Wash. Rev. Code § 9A.04.110 (5) WA § Wash. Rev. Code § 9A.04.020 (4) WA § Wash. Rev. Code § 9A.28.020 (4) WA § Wash. Rev. Code § 10.01.160 (3) WA § Wash. Rev. Code § 9A.04.060 (3) WA § Wash. Rev. Code § 9A.28.030 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 124 (1977–2026) CA 119 (1961–2026) TX 117 (1976–2026) IN 58 (1982–2026) NM 53 (1975–2026) MI 46 (1966–2026) WA 40 (1960–2026) UT 39 (1978–2026) IL 38 (1991–2025) FL 37 (1966–2022) MN 35 (1976–2025) OH 35 (1966–2026) CO 33 (1981–2026) MD 28 (1977–2025) VA 26 (1991–2025) NY 23 (1969–2021) DC 23 (1975–2025) MS 20 (2003–2024) TN 16 (1997–2026) SD 14 (2003–2023) MA 13 (1966–2011) NH 12 (1954–2025) CT 12 (1984–2022) IA 11 (1967–2025) NC 11 (1998–2026) AZ 11 (1979–2025) AK 10 (1979–2024) LA 10 (1961–2016) MO 8 (1995–2023) NJ 8 (1999–2020) VT 8 (2009–2020) GA 7 (1988–2023) KS 7 (1995–2024) OR 7 (1979–2013) ID 7 (1990–2022) HI 6 (1998–2025) RI 6 (1992–2006) OK 6 (1989–2024) VI 5 (2001–2014) ME 4 (2005–2026) GU 4 (2021–2025) WI 4 (1967–2002) AL 4 (1983–2025) SC 3 (2010–2019) ND 3 (2021–2025) DE 3 (2017–2025) WY 3 (1983–2023) NE 3 (1989–2016) AR 2 (2002–2007) NV 2 (2017–2017) MT 2 (2007–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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