In the Matter of the Personal Restraint of: Joseph Andrew Richmond

FILED MARCH 18, 2021 In the Office of the Clerk of Court WA State Court of Appeals, Division III IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE In the Matter of the Personal Restraint of: ) No. 37057-7-III ) JOSEPH ANDREW RICHMOND, ) OPINION PUBLISHED IN PART ) Petitioner. ) PENNELL, C.J. — The use of animal analogies at trial is problematic. Many animal comparisons operate as racist code. Others are simply dehumanizing. But there is no hard and fast rule. Not all animal analogies are inherently improper. When a particular analogy does not clearly convey an improper…