State v. Larson

¶1 — Are ordinary wire cutters “designed to overcome security systems” within the context of retail theft? To answer this question, we must interpret the statutory language of RCW 9A.56.360(l)(b), which elevates retail theft to a more serious offense when the defendant is in possession of “an item, article, implement, or device designed to overcome security systems.”

¶2 We hold that the plain language of RCW 9A.56-.360(l)(b) establishes the legislature’s intent to target organized retail theft only where particular types of tools are utilized. An item, article, implement, or device is…