Petrich unanimity instruction (Washington) · Go Syfert
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Petrich unanimity instruction in Washington

11 Washington opinions name it 1 courts 2009–2025 1 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 (1)

CaseFollowedCited
State v. Craneyellow
wash · 1991 · cited in 4 Washington opinions naming this issue, 2009–2020
2 sentences

2020The State’s attorney presented the jury what he called “options.” Washington courts recognize that a Petrich unanimity instruction is not required when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” State v. Crane, 116 Wn.2d 315, 326 (1991); State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989).

2012Coleman, 159 Wn.2d at 511-12 ; Kitchen, 110 Wn.2d at 409 . ¶35 A Petrich unanimity instruction is not required, however, when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” Crane, 116 Wn.2d at 326 ; State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989); State v. Love, 80 Wn.

14

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 (9)

CaseCitedYears
State v. Handran red
wash · 1989
2 sentences

2020The State’s attorney presented the jury what he called “options.” Washington courts recognize that a Petrich unanimity instruction is not required when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” State v. Crane, 116 Wn.2d 315, 326 (1991); State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989).

2020The State’s attorney presented the jury what he called “options.” Washington courts recognize that a Petrich unanimity instruction is not required when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” State v. Crane, 116 Wn.2d 315, 326 (1991); State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989).

52012–2020
State v. Corbett green
washctapp · 2010
2 sentences

2025In State v. Corbett, 158 Wn. App. 576, 592 , 242 P.3d 52 (2010), we held that where the defendant proposed jury instructions that did not include a Petrich instruction, the invited error doctrine precluded him from challenging on appeal for the first time the trial court’s failure to provide a Petrich unanimity instruction.

2025In State v. Corbett, 158 Wn. App. 576, 592 , 242 P.3d 52 (2010), we held that where the defendant proposed jury instructions that did not include a Petrich instruction, the invited error doctrine precluded him from challenging on appeal for the first time the trial court’s failure to provide a Petrich unanimity instruction.

32014–2025
State v. Kitchen yellow
wash · 2004
2 sentences

2014In a Statement of Additional Grounds for Review SAG), Carson further asserts that ( 1) inconsistent testimony during the child hearsay hearing 1 State v. Petrich, 101 Wn.2d 566, 572 , 683 P. 2d 173 ( 1984), overruled on other grounds by State v. Kitchen, 110 Wn.2d 403 , 405 -06, 756 P. 2d 105 ( 1988). 2 State v. Bone -Club, 128 Wn.2d 254 , 906 P. 2d 325 ( 1995).

2012Coleman, 159 Wn.2d at 511-12 ; Kitchen, 110 Wn.2d at 409 . ¶35 A Petrich unanimity instruction is not required, however, when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” Crane, 116 Wn.2d at 326 ; State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989); State v. Love, 80 Wn.

22012–2014
State v. Boyd green
washctapp · 2007
2 sentences

2019App. 910, 922 , 155 P.3d 188 (2007). 2 No. 78961-9-1/3 defendant is charged with only one count of criminal conduct.”6 The instruction preserves the constitutional right to a unanimous jury verdict by telling the jury that the State must prove a particular criminal act beyond a reasonable doubt and that all jurors must unanimously agree on which act it proved.7 The instruction is unnecessary where the State “‘elect[s] the act upon which it will rely for conviction.”8 An effective election must “‘clearly identif[y] the act upon which the charge in question is based”9 and “disclaim its intention

2019ANALYSIS Hall argues the court failed to give a Petrich unanimity instruction, a manifest constitutional error he may raise for the first time on appeal.4 We review the adequacy of jury instructions de novo.5 A Petrich instruction is appropriate when the evidence in a criminal case “‘indicates that several distinct criminal acts have been committed, but [the] ~ RP (July 31, 2018) at 236, 238. ~ RAP 2.5(a). ~ State v. Boyd, 137 Wn.

12019–2019
State v. Petrich red
wash · 1984
2 sentences

2014In a Statement of Additional Grounds for Review SAG), Carson further asserts that ( 1) inconsistent testimony during the child hearsay hearing 1 State v. Petrich, 101 Wn.2d 566, 572 , 683 P. 2d 173 ( 1984), overruled on other grounds by State v. Kitchen, 110 Wn.2d 403 , 405 -06, 756 P. 2d 105 ( 1988). 2 State v. Bone -Club, 128 Wn.2d 254 , 906 P. 2d 325 ( 1995).

2014In a Statement of Additional Grounds for Review SAG), Carson further asserts that ( 1) inconsistent testimony during the child hearsay hearing 1 State v. Petrich, 101 Wn.2d 566, 572 , 683 P. 2d 173 ( 1984), overruled on other grounds by State v. Kitchen, 110 Wn.2d 403 , 405 -06, 756 P. 2d 105 ( 1988). 2 State v. Bone -Club, 128 Wn.2d 254 , 906 P. 2d 325 ( 1995).

12014–2014
State v. Bone-Club green
wash · 1995
2 sentences

2014In a Statement of Additional Grounds for Review SAG), Carson further asserts that ( 1) inconsistent testimony during the child hearsay hearing 1 State v. Petrich, 101 Wn.2d 566, 572 , 683 P. 2d 173 ( 1984), overruled on other grounds by State v. Kitchen, 110 Wn.2d 403 , 405 -06, 756 P. 2d 105 ( 1988). 2 State v. Bone -Club, 128 Wn.2d 254 , 906 P. 2d 325 ( 1995).

2014In a Statement of Additional Grounds for Review SAG), Carson further asserts that ( 1) inconsistent testimony during the child hearsay hearing 1 State v. Petrich, 101 Wn.2d 566, 572 , 683 P. 2d 173 ( 1984), overruled on other grounds by State v. Kitchen, 110 Wn.2d 403 , 405 -06, 756 P. 2d 105 ( 1988). 2 State v. Bone -Club, 128 Wn.2d 254 , 906 P. 2d 325 ( 1995).

12014–2014
State v. Ellis green
washctapp · 1993
1 sentence

2013State v. Ellis, 71 Wn.

12013–2013
State v. Coleman green
wash · 2007
1 sentence

2012Coleman, 159 Wn.2d at 511-12 ; Kitchen, 110 Wn.2d at 409 . ¶35 A Petrich unanimity instruction is not required, however, when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” Crane, 116 Wn.2d at 326 ; State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989); State v. Love, 80 Wn.

12012–2012
State v. Love green
washctapp · 1996
2 sentences

2012App. 357, 361 , 908 P.2d 395 (1996).

2012Coleman, 159 Wn.2d at 511-12 ; Kitchen, 110 Wn.2d at 409 . ¶35 A Petrich unanimity instruction is not required, however, when the State presents evidence of multiple acts that indicate a “continuing course of conduct.” Crane, 116 Wn.2d at 326 ; State v. Handran, 113 Wn.2d 11, 17 , 775 P.2d 453 (1989); State v. Love, 80 Wn.

12012–2012

Statutes the citing opinions construe

WA § Wash. Rev. Code § 2.06.040 (5)

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.

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