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Keywords

defendantappealcircumstantial evidencedirect evidencebeyond a reasonable doubt

defendantappealtrial

Related Cases

State v. Delmarter, 94 Wash.2d 634, 618 P.2d 99

Facts

Rodney Guy Delmarter was charged with simple assault and attempted theft in the first degree after an incident at Warren's Drug Store. Witnesses did not see him enter the store, but he was found near the prescription counter. Delmarter claimed he entered to retrieve change that had fallen, but the pharmacist found him crouched in front of a cash drawer containing approximately $1,800 in cash. The jury convicted him of simple assault and attempted theft in the first degree, which he appealed.

Defendant, Rodney Guy Delmarter, was charged with simple assault and attempted theft in the first degree of property in Warren's Drug Store. None of the witnesses who testified at trial saw defendant enter the store, nor noticed him until he was near the prescription counter at the back of the store.

Issue

Whether the evidence was sufficient to support a conviction for attempted first-degree theft, specifically regarding the defendant's knowledge of the value of the property involved.

Defendant asserts the evidence is insufficient to prove he had the specific intent to take property valued in excess of $1,500.

Rule

Knowledge of the value of the property is not an element of the crime of attempted first-degree theft, and the sufficiency of evidence is determined by whether any rational trier of fact could find the essential elements of the crime beyond a reasonable doubt.

RCW 9A.56.020 -.030(1)(a) does not include as an element of the crime that defendant must have knowledge of the value of the property.

Analysis

The court applied the rule by reviewing the evidence in the light most favorable to the prosecution. It concluded that a rational trier of fact could find that Delmarter intended to steal from the cash drawer based on his unauthorized presence in a restricted area, his actions in front of the cash drawer, and the circumstances surrounding the incident. The court emphasized that circumstantial evidence is as reliable as direct evidence in establishing intent.

Upon reviewing the evidence in the light most favorable to the State, we conclude that any rational trier of fact could have found the essential elements of attempted theft in the first degree.

Conclusion

The Supreme Court affirmed the conviction for attempted theft in the first degree, concluding that the evidence was sufficient to support the jury's finding of specific intent.

The Court of Appeals is affirmed.

Who won?

The State prevailed in the case because the court found sufficient evidence to support the conviction for attempted first-degree theft, including the defendant's actions and the context of the incident.

The State prevailed in the case because the court found sufficient evidence to support the conviction for attempted first-degree theft.

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