State v. E.J.Y.

— E.J.Y. was adjudicated guilty in juvenile court of felony harassment based on threatening statements he made to a school employee. E.J.Y.’s principal argument on appeal is that the criminal harassment statute, RCW 9A.46.020, is unconstitutionally overbroad and vague under both the federal and state constitutions. We disagree because the statute as written proscribes only true threats, which are unprotected speech. E.J.Y. also argues that he was unconstitutionally restrained during trial. Because this was a bench trial, there was no risk of juror prejudice from viewing the restraints. Thus,…