Wash. Rev. Code » Title 9A · Chapter 9A.32
Revised Code of Washington

Wash. Rev. Code § 9A.32.055 (2026)

Homicide by abuse

✓ current as of May 2026
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(1) A person is guilty of homicide by abuse if, under circumstances manifesting an extreme indifference to human life, the person causes the death of a child or person under sixteen years of age, a developmentally disabled person, or a dependent adult, and the person has previously engaged in a pattern or practice of assault or torture of said child, person under sixteen years of age, developmentally disabled person, or dependent person.
(2) As used in this section, "dependent adult" means a person who, because of physical or mental disability, or because of extreme advanced age, is dependent upon another person to provide the basic necessities of life.
(3) Homicide by abuse is a class A felony.
[ 1987 c 187 s 1.]
Notes of Decisions
Cited in 30 cases (5 in the last 5 years), 1990–2026 · leading case: State v. Creekmore, 783 P.2d 1068 (Wash. Ct. App. 1990).
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State v. Creekmore, 783 P.2d 1068 (Wash. Ct. App. 1990). · cites it 6× “RCW 9A.32.055. The Legislature created this offense in response to a public outcry following Creekmore's crime.”
State v. Womac, 160 P.3d 40 (Wash. 2007). · cites it 2× “RCW 9A.32.055(1). [5] A person is guilty of murder in the second degree when: .”
In re the Pers. Restraint of Gomez, 180 Wash. 2d 337 (Wash. 2014). · cites it 3× “” RCW 9A.32.055(1). It is indisputable that assault is distinct from abuse under Washington law.”
State v. Madarash, 116 Wash. App. 500 (Wash. Ct. App. 2003). · cites it 5× “By amended information, the State charged Madarash with homicide by abuse under RCW 9A.32.055 and second degree felony murder under RCW 9A.”
State v. Russell, 848 P.2d 743 (Wash. Ct. App. 1993). · cites it 4× “Homicide by Abuse The Legislature enacted the homicide by abuse statute, RCW 9A.32.055, 3 in response to the Eli Creekmore killing.”
State v. Womac, 160 Wash. 2d 643 (Wash. 2007). “The majority’s reliance on Womac’s untimely assertion of a state procedural ground for affirmance is inappropriate and unpersuasive.”
State v. Berube, 79 P.3d 1144 (Wash. 2003). “055(1) defines this crime as follows: (1) A person is guilty of homicide by abuse if, under circumstances manifesting an extreme indifference to human life, the person causes the death of a child or person under sixteen years of age, a developmentally disabled person, or a…”
State v. Berube, 150 Wash. 2d 498 (Wash. 2003). “055(1) defines this crime as follows: (1) A person is guilty of homicide by abuse if, under circumstances manifesting an extreme indifference to human life, the person causes the death of a child or person under sixteen years of age, a developmentally disabled person, or a…”
State v. Hall, 230 P.3d 1048 (Wash. 2010). “2 (citing RCW 9A.32.055 (homicide by abuse); RCW 9.”
State v. Hall, 168 Wash. 2d 726 (Wash. 2010). “2 (citing RCW 9A.32.055 (homicide by abuse); RCW 9.”
State v. Madarash, 66 P.3d 682 (Wash. Ct. App. 2003). · cites it 5× “By amended information, the State charged Madarash with homicide by abuse under RCW 9A.32.055 and second degree felony murder under RCW 9A.”
State v. Womac, 123 P.3d 528 (Wash. Ct. App. 2005). “[5] RCW 9A.32.055. [6] RCW 9A.32.050(1)(b). [7] RCW 9A.”
Show all 30 citing cases →
— Wash. Rev. Code § 9A.32.055(1) — 16 cases
State v. Womac, 160 P.3d 40 (Wash. 2007). “RCW 9A.32.055(1). [5] A person is guilty of murder in the second degree when: .”
In re the Pers. Restraint of Gomez, 180 Wash. 2d 337 (Wash. 2014). “” RCW 9A.32.055(1). It is indisputable that assault is distinct from abuse under Washington law.”
State v. Womac, 160 Wash. 2d 643 (Wash. 2007). “The majority’s reliance on Womac’s untimely assertion of a state procedural ground for affirmance is inappropriate and unpersuasive.”
State v. Berube, 79 P.3d 1144 (Wash. 2003). “055(1) defines this crime as follows: (1) A person is guilty of homicide by abuse if, under circumstances manifesting an extreme indifference to human life, the person causes the death of a child or person under sixteen years of age, a developmentally disabled person, or a…”
State v. Berube, 150 Wash. 2d 498 (Wash. 2003). “055(1) defines this crime as follows: (1) A person is guilty of homicide by abuse if, under circumstances manifesting an extreme indifference to human life, the person causes the death of a child or person under sixteen years of age, a developmentally disabled person, or a…”
— Wash. Rev. Code § 9A.32.055(3) — 2 cases
State v. Adams, 155 P.3d 989 (Wash. Ct. App. 2007).
State v. Adams, 138 Wash. App. 36 (Wash. Ct. App. 2007).
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