Wash. Rev. Code » Title 9A · Chapter 9A.56
Revised Code of Washington

Wash. Rev. Code § 9A.56.020 (2026)

✓ current as of May 2026
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(1) "Theft" means:
(a) To wrongfully obtain or exert unauthorized control over the property or services of another or the value thereof, with intent to deprive him or her of such property or services; or
(b) By color or aid of deception to obtain control over the property or services of another or the value thereof, with intent to deprive him or her of such property or services; or
(c) To appropriate lost or misdelivered property or services of another, or the value thereof, with intent to deprive him or her of such property or services.
(2) In any prosecution for theft, it shall be a sufficient defense that:
(a) The property or service was appropriated openly and avowedly under a claim of title made in good faith, even though the claim be untenable; or
(b) The property was merchandise pallets that were received by a pallet recycler or repairer in the ordinary course of its business.
[ 2004 c 122 s 1; 1975-'76 2nd ex.s. c 38 s 9; 1975 1st ex.s. c 260 s 9A.56.020.]

Notes:

Effective date—Severability—1975-'76 2nd ex.s. c 38: See notes following RCW 9A.08.020.
Civil action for shoplifting by adults, minors: RCW 4.24.230.
Notes of Decisions
Cited in 360 cases (38 in the last 5 years), 1978–2026 · leading case: State v. Linehan, 56 P.3d 542 (Wash. 2002).
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State v. Linehan, 56 P.3d 542 (Wash. 2002). · cites it 12× “We hold that any error in defining one alternative means of committing first degree theft was harmless, as there was sufficient evidence for the jury to convict using other definitions for the alternative means set forth in RCW 9A.56.020 under which Linehan was charged.”
State v. Linehan, 147 Wash. 2d 638 (Wash. 2002). · cites it 11× “We hold that any error in defining one alternative means of committing first degree theft was harmless, as there was sufficient evidence for the jury to convict using other definitions for the alternative means set forth in RCW 9A.56.020 under which Linehan was charged.”
In re Disciplinary Proceeding Against Placide, 414 P.3d 1124 (Wash. 2018). · cites it 17× “Did the Board correctly determine that RCW 9A.56.020(1) applies to the theft at issue in count 1? 5.”
State v. Walters, 255 P.3d 835 (Wash. Ct. App. 2011). · cites it 4× “031(1)(g); RCW 9A.56.020; RCW 9A.56.050; RCW 9A.76.040.”
State v. Joy, 851 P.2d 654 (Wash. 1993). · cites it 3× “RCW 9A.56.020 provides in relevant part: (1) "Theft" means: (a) To wrongfully obtain or exert unauthorized, control over the property or services of another or the value thereof, with intent to deprive him of such property or services; or (b) By color or aid of deception to…”
State v. Smith, 154 P.3d 873 (Wash. 2007). · cites it 2× “2d 808 (1985) (separate subsections within RCW 9A.56.020 provide alternative means by which to commit first degree theft).”
State v. Smith, 159 Wash. 2d 778 (Wash. 2007). · cites it 2× “2d 808 (1985) (separate subsections within RCW 9A.56.020 provide alternative means by which to commit first degree theft).”
State v. Delmarter, 618 P.2d 99 (Wash. 1980). · cites it 2× “) Theft is defined in RCW 9A.56.020 as follows: (1) "Theft" means: (a) To wrongfully obtain or exert unauthorized control over the property or services of another or the value thereof, with intent to deprive him of such property or services; .”
State v. Oxborrow, 723 P.2d 1123 (Wash. 1986). · cites it 3× “On October 31, 1984, Oxborrow pleaded guilty to theft in the first degree, RCW 9A.56.020(1)(a), and to willful violation of a cease and desist order concerning the sale of securities, RCW 21.”
State v. Vargas, 683 P.2d 234 (Wash. Ct. App. 1984). · cites it 7× “It is arguable that this was precisely the intent of the Washington Legislature when it codified the crime of theft in RCW 9A.56.020. 2 Although Vargas does not assign error to it, the reference to theft by taking in instruction 8 was erroneous.”
State v. Komok, 783 P.2d 1061 (Wash. 1989). · cites it 5× “Rev. 1 (1972). As originally introduced, the statute included the common law language "intent permanently to deprive.”
State v. Ager, 128 Wash. 2d 85 (Wash. 1995). · cites it 4× “020(1)(a) defines theft by embezzlement as follows: (1) "Theft” means: (a) To wrongfully obtain or exert unauthorized control over the property or services of another or the value thereof, with intent to deprive him of such property or services!.”
Show all 360 citing cases →
— Wash. Rev. Code § 9A.56.020(1) — 53 cases
In re Disciplinary Proceeding Against Placide, 414 P.3d 1124 (Wash. 2018). “Did the Board correctly determine that RCW 9A.56.020(1) applies to the theft at issue in count 1? 5.”
State v. Roberts, 14 P.3d 713 (Wash. 2000).
State v. Ehrhardt, 276 P.3d 332 (Wash. Ct. App. 2012).
State v. Schroeder, 834 P.2d 105 (Wash. Ct. App. 1992).
State v. Laviollette, 826 P.2d 684 (Wash. 1992).
— Wash. Rev. Code § 9A.56.020(1)(a) — 138 cases
State v. Linehan, 56 P.3d 542 (Wash. 2002). “We hold that any error in defining one alternative means of committing first degree theft was harmless, as there was sufficient evidence for the jury to convict using other definitions for the alternative means set forth in RCW 9A.56.020 under which Linehan was charged.”
In re Disciplinary Proceeding Against Placide, 414 P.3d 1124 (Wash. 2018). “Did the Board correctly determine that RCW 9A.56.020(1) applies to the theft at issue in count 1? 5.”
State v. Oxborrow, 723 P.2d 1123 (Wash. 1986). “On October 31, 1984, Oxborrow pleaded guilty to theft in the first degree, RCW 9A.56.020(1)(a), and to willful violation of a cease and desist order concerning the sale of securities, RCW 21.”
State v. Wright, 334 P.3d 22 (Wash. Ct. App. 2014).
In Re Tortorelli, 66 P.3d 606 (Wash. 2003).
— Wash. Rev. Code § 9A.56.020(1)(b) — 34 cases
State v. Mehrabian, 308 P.3d 660 (Wash. Ct. App. 2013).
State v. Fain, 617 P.2d 720 (Wash. 1980).
State v. Vargas, 683 P.2d 234 (Wash. Ct. App. 1984). “It is arguable that this was precisely the intent of the Washington Legislature when it codified the crime of theft in RCW 9A.56.020. 2 Although Vargas does not assign error to it, the reference to theft by taking in instruction 8 was erroneous.”
State v. Newton, 714 P.2d 684 (Wash. Ct. App. 1986).
State v. Pike, 826 P.2d 152 (Wash. 1992).
— Wash. Rev. Code § 9A.56.020(1)(c) — 6 cases
In re Disciplinary Proceeding Against Placide, 414 P.3d 1124 (Wash. 2018). “Did the Board correctly determine that RCW 9A.56.020(1) applies to the theft at issue in count 1? 5.”
State v. George, 164 P.3d 506 (Wash. 2007).
State v. George, 161 Wash. 2d 203 (Wash. 2007).
State v. Perez, 130 Wash. App. 505 (Wash. Ct. App. 2005).
State of Washington v. Shane Robert Malotte (Wash. Ct. App. 2020).
— Wash. Rev. Code § 9A.56.020(2) — 32 cases
State v. Ager, 128 Wash. 2d 85 (Wash. 1995). “020(1)(a) defines theft by embezzlement as follows: (1) "Theft” means: (a) To wrongfully obtain or exert unauthorized control over the property or services of another or the value thereof, with intent to deprive him of such property or services!.”
State v. Ager, 904 P.2d 715 (Wash. 1995).
State v. Trout, 105 P.3d 69 (Wash. Ct. App. 2005).
State v. Trout, 125 Wash. App. 403 (Wash. Ct. App. 2005).
State v. Hicks, 683 P.2d 186 (Wash. 1984).
— Wash. Rev. Code § 9A.56.020(2)(a) — 17 cases
In re Disciplinary Proceeding Against Placide, 414 P.3d 1124 (Wash. 2018). “Did the Board correctly determine that RCW 9A.56.020(1) applies to the theft at issue in count 1? 5.”
In re Disciplinary Proc. Against Huynh, 555 P.3d 398 (Wash. 2024).
State v. Chase, 134 Wash. App. 792 (Wash. Ct. App. 2006).
State Of Washington v. Donna Elizabeth Green (Wash. Ct. App. 2017).
State Of Washington, V James John O'hagan (Wash. Ct. App. 2019).
— Wash. Rev. Code § 9A.56.020(a) — 5 cases
State v. Michielli, 937 P.2d 587 (Wash. 1997).
State v. Roose, 957 P.2d 232 (Wash. Ct. App. 1998).
State v. George, 133 P.3d 487 (Wash. Ct. App. 2006).
In Re Disciplinary Proceedings Against Huddleston, 974 P.2d 325 (Wash. 1999).
OEG Inc v. Korum (W.D. Wash. 2025).
— Wash. Rev. Code § 9A.56.020(b) — 5 cases
State v. George, 133 P.3d 487 (Wash. Ct. App. 2006).
State v. Stephenson, 948 P.2d 1321 (Wash. Ct. App. 1997).
State Of Washington v. Janet Lee Bauml (Wash. Ct. App. 2017).
Robert Luke v. City of Tacoma (9th Cir. 2022).
OEG Inc v. Korum (W.D. Wash. 2025).
— Wash. Rev. Code § 9A.56.020(l) — 1 case
State v. Gerber, 622 P.2d 888 (Wash. Ct. App. 1981).
— Wash. Rev. Code § 9A.56.020(l)(a) — 69 cases
State v. Linehan, 147 Wash. 2d 638 (Wash. 2002). “We hold that any error in defining one alternative means of committing first degree theft was harmless, as there was sufficient evidence for the jury to convict using other definitions for the alternative means set forth in RCW 9A.56.020 under which Linehan was charged.”
State v. Farnsworth, 374 P.3d 1152 (Wash. 2016).
State v. Slemmer, 738 P.2d 281 (Wash. Ct. App. 1987).
In re the Pers. Restraint of Tortorelli, 149 Wash. 2d 82 (Wash. 2003).
State v. Kinneman, 84 P.3d 882 (Wash. Ct. App. 2003).
— Wash. Rev. Code § 9A.56.020(l)(b) — 33 cases
State v. Hassan, 336 P.3d 99 (Wash. Ct. App. 2014).
State v. Heffner, 126 Wash. App. 803 (Wash. Ct. App. 2005).
State v. Love, 309 P.3d 1209 (Wash. Ct. App. 2013).
State v. Fain, 617 P.2d 720 (Wash. 1980).
State v. Stanton, 845 P.2d 1365 (Wash. Ct. App. 1993).
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