Wash. Rev. Code » Title 9A · Chapter 9A.88
Revised Code of Washington

Wash. Rev. Code § 9A.88.010 (2026)

Indecent exposure

✓ current as of May 2026
Find cases: SyfertCases citing this section WA-LEGapp.leg.wa.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar
(1) A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm. The act of breastfeeding or expressing breast milk is not indecent exposure.
(2)(a) Except as provided in (b) and (c) of this subsection, indecent exposure is a misdemeanor.
(b) Indecent exposure is a gross misdemeanor on the first offense if the person exposes himself or herself to a person under the age of fourteen years.
(c) Indecent exposure is a class C felony if the person has previously been convicted under this section or of a sex offense as defined in RCW 9.94A.030.
[ 2003 c 53 s 92; 2001 c 88 s 2; 1990 c 3 s 904; 1987 c 277 s 1; 1975 1st ex.s. c 260 s 9A.88.010.]

Notes:

Intent—Effective date—2003 c 53: See notes following RCW 2.48.180.
Acknowledgment—Declaration—Findings—2001 c 88: See note following RCW 43.70.640.
Notes of Decisions
Cited in 60 cases (7 in the last 5 years), 1977–2026 · leading case: Juan Barrera-Lima v. Jefferson Sessions, III, 901 F.3d 1108 (9th Cir. 2018).
Sort: Relevance Newest Treatment
Juan Barrera-Lima v. Jefferson Sessions, III, 901 F.3d 1108 (9th Cir. 2018). · cites it 49× “2010), the IJ applied the modified categorical approach and concluded that subsection (2) of Wash. Rev. Code § 9A.88.010 was a crime involving moral turpitude because it captured “crime[s] of a sexual nature committed against a protected class of victim.”
State v. Leach, 782 P.2d 552 (Wash. 1989). · cites it 10× “The Court of Appeals concluded that the complaint signed by the investigating police officer and the prosecuting attorney did not state necessary elements of the offense charged; and while the complaint cited RCW 9A.88.010, it did not specify which of the two offenses described…”
State v. Murray, 416 P.3d 1225 (Wash. 2018). · cites it 9× “" RCW 9A.88.010. The statute does not define "obscene.”
State v. Snedden, 73 P.3d 995 (Wash. 2003). · cites it 5× “*919 ISSUE Whether the crime of indecent exposure under RCW 9A.88.010 can serve as the predicate crime for second degree burglary under RCW 9A.”
State v. Vars, 157 Wash. App. 482 (Wash. Ct. App. 2010). · cites it 5× “2 The relevant statute, RCW 9A.88.010, provides, (1) A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm.”
State v. Leach, 766 P.2d 1116 (Wash. Ct. App. 1989). · cites it 10× “*324 Leach was charged in Renton District Court with public indecency pursuant to former RCW 9A.88.010. [1] The complaint, which was prepared by the investigating officer and signed by the prosecuting attorney, provided in pertinent part: The undersigned certifies and says…”
State v. Benitez, 302 P.3d 877 (Wash. Ct. App. 2013). · cites it 4× “RCW 9A.88.010(1) states, “A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm.”
State v. Dubois, 793 P.2d 439 (Wash. Ct. App. 1990). · cites it 10× “— The State of Washington appeals the Superior Court's order affirming the District Court's dismissal of the charge of indecent exposure against Gregory Dubois, arguing that amendments to RCW 9A.88.010 make indecent exposure a crime even if it is not committed in public.”
State Of Washington v. Michael R. Stewart, 457 P.3d 1213 (Wash. Ct. App. 2020). · cites it 2× “78846-9-1/3 The State charged Stewart with indecent exposure under RCW 9A.88.010(1) and (2)(c). Stewart waived his right to ajurytrial.”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010). · cites it 6× “The crime is further elevated to a class C felony if a court has previously convicted the defendant under RCW 9A.88.010 or convicted the defendant of a sex offense as defined in RCW 9.”
State v. Vars, 237 P.3d 378 (Wash. Ct. App. 2010). · cites it 5× “[2] The relevant statute, RCW 9A.88.010, provides, (1) A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm.”
State v. Turner, 103 Wash. App. 515 (Wash. Ct. App. 2000). · cites it 2× “Here, Rogen had a reasonable suspicion that Turner was committing the crime of public indecency, RCW 9A.88.010, 3 when he saw Turner standing with his legs apart, his hands between his legs, and a steady stream of urine.”
Show all 60 citing cases →
— Wash. Rev. Code § 9A.88.010(1) — 28 cases
Juan Barrera-Lima v. Jefferson Sessions, III, 901 F.3d 1108 (9th Cir. 2018). “2010), the IJ applied the modified categorical approach and concluded that subsection (2) of Wash. Rev. Code § 9A.88.010 was a crime involving moral turpitude because it captured “crime[s] of a sexual nature committed against a protected class of victim.”
State Of Washington v. Michael R. Stewart, 457 P.3d 1213 (Wash. Ct. App. 2020). “78846-9-1/3 The State charged Stewart with indecent exposure under RCW 9A.88.010(1) and (2)(c). Stewart waived his right to ajurytrial.”
State v. Snedden, 73 P.3d 995 (Wash. 2003). “*919 ISSUE Whether the crime of indecent exposure under RCW 9A.88.010 can serve as the predicate crime for second degree burglary under RCW 9A.”
State v. Murray, 416 P.3d 1225 (Wash. 2018). “" RCW 9A.88.010. The statute does not define "obscene.”
State v. Vars, 157 Wash. App. 482 (Wash. Ct. App. 2010). “2 The relevant statute, RCW 9A.88.010, provides, (1) A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm.”
— Wash. Rev. Code § 9A.88.010(1)(1990) — 1 case
State v. Snedden, 47 P.3d 184 (Wash. Ct. App. 2002).
— Wash. Rev. Code § 9A.88.010(1)(c) — 1 case
State Of Washington v. Terrence Patrick Eckhart (Wash. Ct. App. 2016).
— Wash. Rev. Code § 9A.88.010(2) — 8 cases
State v. Leach, 782 P.2d 552 (Wash. 1989). “The Court of Appeals concluded that the complaint signed by the investigating police officer and the prosecuting attorney did not state necessary elements of the offense charged; and while the complaint cited RCW 9A.88.010, it did not specify which of the two offenses described…”
Juan Barrera-Lima v. Jefferson Sessions, III, 901 F.3d 1108 (9th Cir. 2018). “2010), the IJ applied the modified categorical approach and concluded that subsection (2) of Wash. Rev. Code § 9A.88.010 was a crime involving moral turpitude because it captured “crime[s] of a sexual nature committed against a protected class of victim.”
State v. Snedden, 73 P.3d 995 (Wash. 2003). “*919 ISSUE Whether the crime of indecent exposure under RCW 9A.88.010 can serve as the predicate crime for second degree burglary under RCW 9A.”
State v. Leach, 766 P.2d 1116 (Wash. Ct. App. 1989). “*324 Leach was charged in Renton District Court with public indecency pursuant to former RCW 9A.88.010. [1] The complaint, which was prepared by the investigating officer and signed by the prosecuting attorney, provided in pertinent part: The undersigned certifies and says…”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010). “The crime is further elevated to a class C felony if a court has previously convicted the defendant under RCW 9A.88.010 or convicted the defendant of a sex offense as defined in RCW 9.”
— Wash. Rev. Code § 9A.88.010(2)(a) — 2 cases
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010). “The crime is further elevated to a class C felony if a court has previously convicted the defendant under RCW 9A.88.010 or convicted the defendant of a sex offense as defined in RCW 9.”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010).
— Wash. Rev. Code § 9A.88.010(2)(b) — 4 cases
Juan Barrera-Lima v. Jefferson Sessions, III, 901 F.3d 1108 (9th Cir. 2018). “2010), the IJ applied the modified categorical approach and concluded that subsection (2) of Wash. Rev. Code § 9A.88.010 was a crime involving moral turpitude because it captured “crime[s] of a sexual nature committed against a protected class of victim.”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010). “The crime is further elevated to a class C felony if a court has previously convicted the defendant under RCW 9A.88.010 or convicted the defendant of a sex offense as defined in RCW 9.”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010).
State Of Washington, V Fernando P. Hodgson (Wash. Ct. App. 2016).
— Wash. Rev. Code § 9A.88.010(2)(c) — 11 cases
State v. Benitez, 302 P.3d 877 (Wash. Ct. App. 2013). “RCW 9A.88.010(1) states, “A person is guilty of indecent exposure if he or she intentionally makes any open and obscene exposure of his or her person or the person of another knowing that such conduct is likely to cause reasonable affront or alarm.”
State v. Murray, 416 P.3d 1225 (Wash. 2018). “" RCW 9A.88.010. The statute does not define "obscene.”
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010). “The crime is further elevated to a class C felony if a court has previously convicted the defendant under RCW 9A.88.010 or convicted the defendant of a sex offense as defined in RCW 9.”
State v. Bache, 146 Wash. App. 897 (Wash. Ct. App. 2008).
State v. Steen, 228 P.3d 1285 (Wash. Ct. App. 2010).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.