State v. Laico

The definition of “great bodily harm” contained in RCW 9A.04.110(4)(c) is merely definitional and does not create alternative means of committing the crime of assault in the first degree. Therefore, jury unanimity with respect to the existence of great bodily harm does not require unanimity as to the type of great bodily harm. We reverse and remand for a new trial, however, because the court failed to instruct the jury on the lesser included offense of assault in the fourth degree when there was evidence supporting an inference that Laico committed only the lesser crime.

FACTS

Bahram Ahmadi was…