Wash. Rev. Code » Title 9A · Chapter 9A.36
Revised Code of Washington

Wash. Rev. Code § 9A.36.100 (2026)

Custodial assault

✓ current as of May 2026
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(1) A person is guilty of custodial assault if that person is not guilty of an assault in the first or second degree and where the person:
(a) Assaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any juvenile corrections institution or local juvenile detention facilities who was performing official duties at the time of the assault;
(b) Assaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections institution or local adult detention facilities who was performing official duties at the time of the assault;
(c)(i) Assaults a full or part-time community correction officer while the officer is performing official duties; or
(ii) Assaults any other full or part-time employee who is employed in a community corrections office while the employee is performing official duties; or
(d) Assaults any volunteer who was assisting a person described in (c) of this subsection at the time of the assault.
(2) Custodial assault is a class C felony.
[ 1988 c 151 s 1; 1987 c 188 s 1.]

Notes:

Effective date—1987 c 188: "This act is necessary for the immediate preservation of the public peace, health, and safety, the support of the state government and its existing public institutions, and shall take effect July 1, 1987." [ 1987 c 188 s 3.]
Notes of Decisions
Cited in 27 cases (3 in the last 5 years), 1988–2021 · leading case: State v. Mathews, 807 P.2d 890 (Wash. Ct. App. 1991).
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State v. Mathews, 807 P.2d 890 (Wash. Ct. App. 1991). · cites it 5× “Mathews appeals his conviction for custodial assault in violation of RCW 9A.36.100. He contends that the State charged him with a constitutionally defective information which omitted an essential element of the offense, and thus failed to confer subject matter jurisdiction on…”
State v. Bradley, 10 P.3d 358 (Wash. 2000). · cites it 2× “We affirm Alonzo Bradley’s conviction for custodial assault pursuant to RCW 9A.36.100(l)(b). ISSUE When a person claims to be using force in self-defense to the actions of a correctional officer, must the person show he or she was in actual, imminent danger of serious injury, or…”
State v. Ashcraft, 859 P.2d 60 (Wash. Ct. App. 1993). “RCW 9A.36.100. 3 Similarly, the belt bruise marks seen by the doctors and J.”
Monroe v. Soliz, 939 P.2d 205 (Wash. 1997). “(4) Upon conviction in a court of law for custodial assault as defined in RCW 9A.36.100, the department of social and health services review board shall conduct a second hearing, within five judicial working days, to recommend to the secretary of the department of social and…”
State v. Bush, 102 Wash. App. 372 (Wash. Ct. App. 2000). · cites it 4× “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person “[ajssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State v. Cook, 760 P.2d 964 (Wash. Ct. App. 1988). · cites it 2× “Former RCW 9A.36.100(1)(b). The provision became effective on July 1, 1987.”
State v. Radcliff, 794 P.2d 869 (Wash. Ct. App. 1990). · cites it 2× “The State also argues that the offense could have been charged as custodial assault, RCW 9A.36.100(1)(a). 3 We agree that the crime committed here is more serious than the usual fourth degree assault because the victim is a staff member in a rehabilitation facility.”
State of Washington v. Donald Joseph Gabriel Zack, 413 P.3d 65 (Wash. Ct. App. 2018). “Zack attempts to distinguish McLean by pointing to the subsequent enactment of the custodial assault statute,RCW 9A.36.100(l)(b),and suggesting that was the more appropriate charge for this case.”
State v. Bradley, 980 P.2d 235 (Wash. Ct. App. 1999). “Bradley was charged with two counts of custodial assault under RCW 9A.36.100(l)(b), pertaining respectively to the alleged assaults on Sergeant Snodgrass and Officer Red-man.”
State v. Bradley, 980 P.2d 235 (Wash. Ct. App. 1999). “Bradley was charged with two counts of custodial assault under RCW 9A.36.100(1)(b), pertaining respectively to the alleged assaults on Sergeant Snodgrass and Officer Redman.”
State v. Bush, 9 P.3d 219 (Wash. Ct. App. 2000). · cites it 4× “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person "[a]ssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State v. Garcia, 27 P.3d 1225 (Wash. Ct. App. 2001). · cites it 2× “Applying the Bradley rule to Garcia does not violate his due process right to fair warning of the conduct proscribed by RCW 9A.36.100. Affirmed. We concur: MORGAN, P.”
Show all 27 citing cases →
— Wash. Rev. Code § 9A.36.100(1) — 6 cases
State v. Contreras, 856 P.2d 397 (Wash. Ct. App. 1993).
State v. C.B., 265 P.3d 951 (Wash. Ct. App. 2011).
State Of Washington, V. James D. Griepsma, Jr. (Wash. Ct. App. 2021).
State Of Washington v. Dakota Lazier (Wash. Ct. App. 2016).
State Of Washington v. N.m. (Wash. Ct. App. 2016).
— Wash. Rev. Code § 9A.36.100(1)(a) — 7 cases
State v. Radcliff, 794 P.2d 869 (Wash. Ct. App. 1990). “The State also argues that the offense could have been charged as custodial assault, RCW 9A.36.100(1)(a). 3 We agree that the crime committed here is more serious than the usual fourth degree assault because the victim is a staff member in a rehabilitation facility.”
State v. Garcia, 27 P.3d 1225 (Wash. Ct. App. 2001). “Applying the Bradley rule to Garcia does not violate his due process right to fair warning of the conduct proscribed by RCW 9A.36.100. Affirmed. We concur: MORGAN, P.”
State v. Garcia, 107 Wash. App. 545 (Wash. Ct. App. 2001).
State Of Washington v. N.m. (Wash. Ct. App. 2016).
State Of Washington v. K.A.B. (Wash. Ct. App. 2020).
— Wash. Rev. Code § 9A.36.100(1)(b) — 7 cases
State v. Cook, 760 P.2d 964 (Wash. Ct. App. 1988). “Former RCW 9A.36.100(1)(b). The provision became effective on July 1, 1987.”
State v. Bush, 102 Wash. App. 372 (Wash. Ct. App. 2000). “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person “[ajssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State v. Bradley, 980 P.2d 235 (Wash. Ct. App. 1999). “Bradley was charged with two counts of custodial assault under RCW 9A.36.100(1)(b), pertaining respectively to the alleged assaults on Sergeant Snodgrass and Officer Redman.”
State v. Bush, 9 P.3d 219 (Wash. Ct. App. 2000). “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person "[a]ssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State Of Washington v. Terrence L. Lavery (Wash. Ct. App. 2018).
— Wash. Rev. Code § 9A.36.100(1)(c)(i) — 3 cases
State v. Bush, 102 Wash. App. 372 (Wash. Ct. App. 2000). “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person “[ajssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State v. Bush, 9 P.3d 219 (Wash. Ct. App. 2000). “100(1)(b) states that a person is guilty of the class C felony of custodial assault if the person "[a]ssaults a full or part-time staff member or volunteer, any educational personnel, any personal service provider, or any vendor or agent thereof at any adult corrections…”
State v. Bradley, 10 P.3d 358 (Wash. 2000).
— Wash. Rev. Code § 9A.36.100(2) — 1 case
State Of Washington v. Terrence L. Lavery (Wash. Ct. App. 2018).
— Wash. Rev. Code § 9A.36.100(l)(b) — 5 cases
State v. Bradley, 10 P.3d 358 (Wash. 2000). “We affirm Alonzo Bradley’s conviction for custodial assault pursuant to RCW 9A.36.100(l)(b). ISSUE When a person claims to be using force in self-defense to the actions of a correctional officer, must the person show he or she was in actual, imminent danger of serious injury, or…”
State of Washington v. Donald Joseph Gabriel Zack, 413 P.3d 65 (Wash. Ct. App. 2018). “Zack attempts to distinguish McLean by pointing to the subsequent enactment of the custodial assault statute,RCW 9A.36.100(l)(b),and suggesting that was the more appropriate charge for this case.”
State v. Bradley, 980 P.2d 235 (Wash. Ct. App. 1999). “Bradley was charged with two counts of custodial assault under RCW 9A.36.100(l)(b), pertaining respectively to the alleged assaults on Sergeant Snodgrass and Officer Red-man.”
State v. Mathews, 807 P.2d 890 (Wash. Ct. App. 1991). “Mathews appeals his conviction for custodial assault in violation of RCW 9A.36.100. He contends that the State charged him with a constitutionally defective information which omitted an essential element of the offense, and thus failed to confer subject matter jurisdiction on…”
State v. Ratliff, 892 P.2d 118 (Wash. Ct. App. 1995).
— Wash. Rev. Code § 9A.36.100(l)(c)(i) — 1 case
State v. Bradley, 10 P.3d 358 (Wash. 2000). “We affirm Alonzo Bradley’s conviction for custodial assault pursuant to RCW 9A.36.100(l)(b). ISSUE When a person claims to be using force in self-defense to the actions of a correctional officer, must the person show he or she was in actual, imminent danger of serious injury, or…”
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