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

Wash. Rev. Code § 9A.56.130 (2026)

Extortion in the second degree

✓ current as of May 2026
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(1) A person is guilty of extortion in the second degree if he or she commits extortion by means of a wrongful threat as defined in RCW 9A.04.110(28) (d) through (j).
(2) In any prosecution under this section based on a threat to accuse any person of a crime or cause criminal charges to be instituted against any person, it is a defense that the actor reasonably believed the threatened criminal charge to be true and that his or her sole purpose was to compel or induce the person threatened to take reasonable action to make good the wrong which was the subject of such threatened criminal charge.
(3) Extortion in the second degree is a class C felony.
[ 2018 c 22 s 5; 2002 c 47 s 2; 1975 1st ex.s. c 260 s 9A.56.130.]

Notes:

Explanatory statement—2018 c 22: See note following RCW 1.20.051.
Intent—2002 c 47: "The legislature intends to revise the crime of extortion in the second degree in response to the holding in State v. Pauling, 108 Wn. App. 445 (2001), by adding a requirement that the threat required for conviction of the offense be wrongful." [ 2002 c 47 s 1.]
Notes of Decisions
Cited in 21 cases (4 in the last 5 years), 1980–2025 · leading case: State v. Pauling, 69 P.3d 331 (Wash. 2003).
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State v. Pauling, 69 P.3d 331 (Wash. 2003). · cites it 11× “The Court of Appeals, stating that the statute lacked a requirement that the threat be wrongful, declared former RCW 9A.”
State v. Pauling, 149 Wash. 2d 381 (Wash. 2003). · cites it 10× “Pauling was convicted of second degree extortion under former RCW 9A.56.130 (1975) for threatening to disseminate and, in actuality, disseminating nude photos of a former girl friend to collect a valid $5,000 small claims court judgment he had against her.”
State v. Smith, 610 P.2d 869 (Wash. 1980). · cites it 2× “040; extortion in the *364 second degree, RCW 9A.56.130; first-degree reckless burning, RCW 9A.”
United States v. Brian R. Anderson, 989 F.2d 310 (9th Cir. 1993). · cites it 4× “Again, RCW 9A.56.130(1) doesn’t fit this definition, because the nonviolent threats to which it applies rarely lead to physical injury.”
State v. E.J.Y., 55 P.3d 673 (Wash. Ct. App. 2002). “Pauling 33 which held that the extortion statute, RCW 9A.56.130, was unconstitutionally overbroad, 34 should be applied to the criminal harassment statute, therefore rendering it unconstitutional.”
State v. Marko, 27 P.3d 228 (Wash. Ct. App. 2001). “Garvin , a case directly on point, analyzed the precise definitional statute applicable here; the court found that "[s]econd degree extortion pursuant to RCW 9A.56.130 is extortion committed by means of a `threat' which is defined by RCW 9A.”
State v. Marko, 107 Wash. App. 215 (Wash. Ct. App. 2001). “Garvin, a case directly on point, analyzed the precise definitional statute applicable here; the court found that “[s]econd degree extortion pursuant to RCW 9A.56.130 is extortion committed by means of a ‘threat’ which is defined by RCW 9A.”
State v. Strong, 272 P.3d 281 (Wash. Ct. App. 2012). · cites it 2× “But she does not ask us to invalidate the statute on that basis; she asks, instead, that we construe it to require proof of a true threat, which she argues is essential to preserve its constitutionality.”
State v. Strohm, 879 P.2d 962 (Wash. Ct. App. 1994). “2d 1017 (1981), this court held that "[s]econd degree extortion pursuant to RCW 9A.56.130 is extortion committed by means of a 'threat’ which is defined by RCW 9A.”
State v. Garvin, 621 P.2d 215 (Wash. Ct. App. 1980). “" Second degree extortion pursuant to RCW 9A.56.130 is extortion committed by means of a "threat" which is defined by RCW 9A.”
Nelson v. McGoldrick, 871 P.2d 177 (Wash. Ct. App. 1994). · cites it 2× “" An "owner" is a person who "has possession of or any other interest in the property or services involved".”
State v. Pauling, 31 P.3d 47 (Wash. Ct. App. 2001). “Pauling was convicted of extortion in the second degree under RCW 9A.56.130. That statute provides in part: (1) A person is guilty of extortion in the second degree if he commits extortion by means of a threat as defined in RCW 9A.”
Show all 21 citing cases →
— Wash. Rev. Code § 9A.56.130(1) — 2 cases
United States v. Brian R. Anderson, 989 F.2d 310 (9th Cir. 1993). “Again, RCW 9A.56.130(1) doesn’t fit this definition, because the nonviolent threats to which it applies rarely lead to physical injury.”
Nelson v. McGoldrick, 871 P.2d 177 (Wash. Ct. App. 1994). “" An "owner" is a person who "has possession of or any other interest in the property or services involved".”
— Wash. Rev. Code § 9A.56.130(2) — 3 cases
State v. Pauling, 69 P.3d 331 (Wash. 2003). “The Court of Appeals, stating that the statute lacked a requirement that the threat be wrongful, declared former RCW 9A.”
State v. Pauling, 149 Wash. 2d 381 (Wash. 2003). “Pauling was convicted of second degree extortion under former RCW 9A.56.130 (1975) for threatening to disseminate and, in actuality, disseminating nude photos of a former girl friend to collect a valid $5,000 small claims court judgment he had against her.”
State of Washington v. Henry F. Ward, Jr (Wash. Ct. App. 2025).
— Wash. Rev. Code § 9A.56.130(l) — 1 case
United States v. Brian R. Anderson, 989 F.2d 310 (9th Cir. 1993). “Again, RCW 9A.56.130(1) doesn’t fit this definition, because the nonviolent threats to which it applies rarely lead to physical injury.”
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