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

Wash. Rev. Code § 9A.56.200 (2026)

Robbery in the first degree

✓ current as of May 2026
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(1) A person is guilty of robbery in the first degree if:
(a) In the commission of a robbery or of immediate flight therefrom, he or she:
(i) Is armed with a deadly weapon; or
(ii) Displays what appears to be a firearm or other deadly weapon; or
(iii) Inflicts bodily injury; or
(b) He or she commits a robbery within and against a financial institution as defined in RCW 7.88.010 or 35.38.060.
(2) Robbery in the first degree is a class A felony.
[ 2002 c 85 s 1; 1975 1st ex.s. c 260 s 9A.56.200.]
Notes of Decisions
Cited in 315 cases (47 in the last 5 years), 1977–2026 · leading case: State v. Kier, 194 P.3d 212 (Wash. 2008).
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State v. Kier, 194 P.3d 212 (Wash. 2008). · cites it 5× “The merger doctrine is triggered when second degree assault with a deadly weapon elevates robbery to the first degree because being armed with or displaying a firearm or deadly weapon to take property through force or fear is essential to the elevation.”
State v. Tvedt, 153 Wash. 2d 705 (Wash. 2005). · cites it 5× “260, at 841, 846 (RCW 9A.56.200). Offenses included in the chapter, as codified in 1975, are theft, unlawful issuance of checks, taking motor vehicle without permission, theft of livestock, theft presumed from the failure to return leased items, extortion, possession of stolen…”
State v. Tvedt, 107 P.3d 728 (Wash. 2005). · cites it 5× “RCW 9A.56.200 and .210 then go on to define first and second degree robbery respectively.”
In Re the Pers. Restraint of Carle, 604 P.2d 1293 (Wash. 1980). · cites it 7× “Petitioner was charged with first-degree robbery while armed with a deadly weapon, pursuant to RCW 9A.56.200 and RCW 9.95.015. He pleaded guilty and admitted he was so armed.”
State v. Hentz, 663 P.2d 476 (Wash. 1983). · cites it 8× “040(1)(a) with the robbery statute, RCW 9A.56.200, which specifically provides that a person is guilty of first degree robbery if *545 during the commission of the crime he is "armed with a deadly weapon" or "[d]isplays what appears to be a .”
State v. Workman, 584 P.2d 382 (Wash. 1978). · cites it 3× “Likewise, the element of circumstances warranting alarm under the lesser offense is an inherent characteristic of an attempt to commit a robbery.”
Jones v. United States, 526 U.S. 227 (1999). · cites it 2× “§ 76-6-302 (1)(b) (1995) (aggravated robbery; "causes serious bodily injury"); Wash. Rev. Code § 9A.56.200(1)(c) (1994) (robbery in the first degree; "[i]nflicts bodily injury").”
In re the Pers. Restraint of Francis, 170 Wash. 2d 517 (Wash. 2010). · cites it 4× “¶19 The State also argues the second degree assault conduct need not be part of the attempted first degree robbery charge because Francis was armed with and/or displayed a deadly weapon (a baseball bat) in his attempt, and thus his attempted robbery is alternatively elevated to…”
State v. Freeman, 108 P.3d 753 (Wash. 2005). · cites it 2× “Compare RCW 9A.56.200 (first degree robbery) with RCW 9A.”
State v. Adlington-Kelly, 631 P.2d 954 (Wash. 1981). · cites it 8× “Evidence of such legislative intent was absent under the robbery statute, RCW 9A.56.200 and .210 [4] In fact, the legislature in 1975 specifically addressed firearms use during the commission of robberies by enacting degrees.”
State v. Davis, 682 P.2d 883 (Wash. 1984). · cites it 4× “First degree robbery is defined in RCW 9A.56.200, and is designated a class A felony.”
Stokeling v. United States, 139 S. Ct. 544 (2019). “2-58 (2014) ; Wash. Rev. Code §§ 9A.56.200(1)(a)(ii)-(iii) (2015); W.”
Show all 315 citing cases →
— Wash. Rev. Code § 9A.56.200(1) — 30 cases
State v. McKague, 159 Wash. App. 489 (Wash. Ct. App. 2011).
State v. Hentz, 663 P.2d 476 (Wash. 1983). “040(1)(a) with the robbery statute, RCW 9A.56.200, which specifically provides that a person is guilty of first degree robbery if *545 during the commission of the crime he is "armed with a deadly weapon" or "[d]isplays what appears to be a .”
State v. Koslowski, 209 P.3d 479 (Wash. 2009).
State v. Koslowski, 166 Wash. 2d 409 (Wash. 2009).
Fields v. Wash. Dep't of Early Learning, 434 P.3d 999 (Wash. 2019).
— Wash. Rev. Code § 9A.56.200(1)(1975) — 1 case
Fields v. Wash. Dep't of Early Learning, 434 P.3d 999 (Wash. 2019).
— Wash. Rev. Code § 9A.56.200(1)(6) — 1 case
State v. Beaton, 659 P.2d 1129 (Wash. Ct. App. 1983).
— Wash. Rev. Code § 9A.56.200(1)(a) — 29 cases
State v. Hentz, 663 P.2d 476 (Wash. 1983). “040(1)(a) with the robbery statute, RCW 9A.56.200, which specifically provides that a person is guilty of first degree robbery if *545 during the commission of the crime he is "armed with a deadly weapon" or "[d]isplays what appears to be a .”
State v. Chesnokov, 305 P.3d 1103 (Wash. Ct. App. 2013).
State v. Davis, 682 P.2d 883 (Wash. 1984). “First degree robbery is defined in RCW 9A.56.200, and is designated a class A felony.”
State v. Nicholas, 776 P.2d 1385 (Wash. Ct. App. 1989).
State v. Martinez, 86 P.3d 1210 (Wash. Ct. App. 2004).
— Wash. Rev. Code § 9A.56.200(1)(a)(b) — 2 cases
State v. Kjorsvik, 812 P.2d 86 (Wash. 1991).
State v. Champion, 140 P.3d 633 (Wash. Ct. App. 2006).
— Wash. Rev. Code § 9A.56.200(1)(a)(c) — 1 case
State v. Irizarry, 763 P.2d 432 (Wash. 1988).
— Wash. Rev. Code § 9A.56.200(1)(a)(i) — 30 cases
State v. Kelley, 168 Wash. 2d 72 (Wash. 2010).
State v. Kelley, 226 P.3d 773 (Wash. 2010).
State v. Chesnokov, 305 P.3d 1103 (Wash. Ct. App. 2013).
State v. Esparza, 143 P.3d 612 (Wash. Ct. App. 2006).
In Re Francis, 242 P.3d 866 (Wash. 2010).
— Wash. Rev. Code § 9A.56.200(1)(a)(i)(ii) — 2 cases
State v. Crawford, 115 P.3d 387 (Wash. Ct. App. 2005).
State of Washington v. Rondale Haze Pleasant (Wash. Ct. App. 2015).
— Wash. Rev. Code § 9A.56.200(1)(a)(ii) — 14 cases
Stokeling v. United States, 139 S. Ct. 544 (2019). “2-58 (2014) ; Wash. Rev. Code §§ 9A.56.200(1)(a)(ii)-(iii) (2015); W.”
State v. Webb, 162 Wash. App. 195 (Wash. Ct. App. 2011).
State Of Washington v. S.D.H., 484 P.3d 538 (Wash. Ct. App. 2021).
State v. Webb, 252 P.3d 424 (Wash. Ct. App. 2011).
Pers. Restraint Petition Of: Bobby Joe Ezra Plain (Wash. Ct. App. 2024).
— Wash. Rev. Code § 9A.56.200(1)(a)(iii) — 25 cases
State v. Lewis, 233 P.3d 891 (Wash. Ct. App. 2010).
In Re Francis, 242 P.3d 866 (Wash. 2010).
State Of Washington, V. Alfonso Aguilar, 534 P.3d 360 (Wash. Ct. App. 2023).
State v. Truong, 168 Wash. App. 529 (Wash. Ct. App. 2012).
State v. Truong, 277 P.3d 74 (Wash. Ct. App. 2012).
— Wash. Rev. Code § 9A.56.200(1)(b) — 26 cases
State v. Nicholas, 776 P.2d 1385 (Wash. Ct. App. 1989).
State v. Bisson, 130 P.3d 820 (Wash. 2006).
State v. Louis, 120 P.3d 936 (Wash. 2005).
State v. Beals, 997 P.2d 941 (Wash. Ct. App. 2000).
State v. Martinez, 86 P.3d 1210 (Wash. Ct. App. 2004).
— Wash. Rev. Code § 9A.56.200(1)(c) — 3 cases
Jones v. United States, 526 U.S. 227 (1999). “§ 76-6-302 (1)(b) (1995) (aggravated robbery; "causes serious bodily injury"); Wash. Rev. Code § 9A.56.200(1)(c) (1994) (robbery in the first degree; "[i]nflicts bodily injury").”
State v. Adlington-Kelly, 631 P.2d 954 (Wash. 1981). “Evidence of such legislative intent was absent under the robbery statute, RCW 9A.56.200 and .210 [4] In fact, the legislature in 1975 specifically addressed firearms use during the commission of robberies by enacting degrees.”
State v. Wade, 138 P.3d 168 (Wash. Ct. App. 2006).
— Wash. Rev. Code § 9A.56.200(1)(ii) — 1 case
United States v. Tre Tate, 999 F.3d 374 (6th Cir. 2021).
— Wash. Rev. Code § 9A.56.200(1)(iii) — 1 case
State Of Washington, V. Jeremy Fenney (Wash. Ct. App. 2021).
— Wash. Rev. Code § 9A.56.200(2) — 33 cases
State v. Fain, 617 P.2d 720 (Wash. 1980).
State v. Chavez, 180 P.3d 1250 (Wash. 2008).
State v. Russell, 16 P.3d 664 (Wash. Ct. App. 2001).
State v. Russell, 104 Wash. App. 422 (Wash. Ct. App. 2001).
In re the Pers. Restraint of McKiearnan, 165 Wash. 2d 777 (Wash. 2009).
— Wash. Rev. Code § 9A.56.200(a)(i) — 1 case
State of Washington v. Parker M. Bachtold (Wash. Ct. App. 2025).
— Wash. Rev. Code § 9A.56.200(l)(a) — 11 cases
In re the Pers. Restraint of Brockie, 309 P.3d 498 (Wash. 2013).
State v. Davis, 682 P.2d 883 (Wash. 1984). “First degree robbery is defined in RCW 9A.56.200, and is designated a class A felony.”
State v. Barry, 611 P.2d 1262 (Wash. Ct. App. 1980).
State v. Nguyen, 847 P.2d 936 (Wash. Ct. App. 1993).
State v. Wheeler, 593 P.2d 550 (Wash. Ct. App. 1979).
— Wash. Rev. Code § 9A.56.200(l)(a)(b) — 1 case
State v. Kjorsvik, 812 P.2d 86 (Wash. 1991).
— Wash. Rev. Code § 9A.56.200(l)(a)(i) — 10 cases
State v. Kier, 194 P.3d 212 (Wash. 2008). “The merger doctrine is triggered when second degree assault with a deadly weapon elevates robbery to the first degree because being armed with or displaying a firearm or deadly weapon to take property through force or fear is essential to the elevation.”
State v. Knight, 309 P.3d 776 (Wash. Ct. App. 2013).
In re the Pers. Restraint of Francis, 170 Wash. 2d 517 (Wash. 2010). “¶19 The State also argues the second degree assault conduct need not be part of the attempted first degree robbery charge because Francis was armed with and/or displayed a deadly weapon (a baseball bat) in his attempt, and thus his attempted robbery is alternatively elevated to…”
State v. McDaniel, 155 Wash. App. 829 (Wash. Ct. App. 2010).
State v. Esparza, 143 P.3d 612 (Wash. Ct. App. 2006).
— Wash. Rev. Code § 9A.56.200(l)(a)(ii) — 6 cases
State v. Kier, 194 P.3d 212 (Wash. 2008). “The merger doctrine is triggered when second degree assault with a deadly weapon elevates robbery to the first degree because being armed with or displaying a firearm or deadly weapon to take property through force or fear is essential to the elevation.”
State v. Berg, 337 P.3d 310 (Wash. 2014).
State v. Webb, 162 Wash. App. 195 (Wash. Ct. App. 2011).
State v. Lindsay, 288 P.3d 641 (Wash. Ct. App. 2012).
State of Washington v. Maxwell Delvon Jones (Wash. Ct. App. 2017).
— Wash. Rev. Code § 9A.56.200(l)(a)(iii) — 5 cases
In re the Pers. Restraint of Francis, 170 Wash. 2d 517 (Wash. 2010). “¶19 The State also argues the second degree assault conduct need not be part of the attempted first degree robbery charge because Francis was armed with and/or displayed a deadly weapon (a baseball bat) in his attempt, and thus his attempted robbery is alternatively elevated to…”
State v. Lewis, 233 P.3d 891 (Wash. Ct. App. 2010).
State v. Johnson, 155 Wash. 2d 609 (Wash. 2005).
State v. Zumwalt, 82 P.3d 672 (Wash. Ct. App. 2003).
State v. Bauer, 295 P.3d 1227 (Wash. Ct. App. 2013).
— Wash. Rev. Code § 9A.56.200(l)(b) — 16 cases
State v. Kier, 194 P.3d 212 (Wash. 2008). “The merger doctrine is triggered when second degree assault with a deadly weapon elevates robbery to the first degree because being armed with or displaying a firearm or deadly weapon to take property through force or fear is essential to the elevation.”
State v. Farnsworth, 374 P.3d 1152 (Wash. 2016).
State v. Henderson, 664 P.2d 1291 (Wash. Ct. App. 1983).
State v. Thorne, 921 P.2d 514 (Wash. 1996).
State v. Bisson, 130 P.3d 820 (Wash. 2006).
— Wash. Rev. Code § 9A.56.200(l)(c) — 4 cases
Jones v. United States, 526 U.S. 227 (1999). “§ 76-6-302 (1)(b) (1995) (aggravated robbery; "causes serious bodily injury"); Wash. Rev. Code § 9A.56.200(1)(c) (1994) (robbery in the first degree; "[i]nflicts bodily injury").”
State v. Latham, 670 P.2d 689 (Wash. Ct. App. 1983).
State v. Adlington-Kelly, 631 P.2d 954 (Wash. 1981). “Evidence of such legislative intent was absent under the robbery statute, RCW 9A.56.200 and .210 [4] In fact, the legislature in 1975 specifically addressed firearms use during the commission of robberies by enacting degrees.”
State v. Wade, 133 Wash. App. 855 (Wash. Ct. App. 2006).
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