State v. Lilyblad

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This case presents a conflict in the Court of Appeals regarding whether the crime of telephone harassment, RCW 9.61.230,1 requires the State to prove that a defendant formed the specific intent to harass the victim at the initiation of a call, or at any time during the call. The Court of Appeals, Division Two, reversed Stephanie Paris’s conviction based on an improper jury instruction as to when the specific intent of that crime must form. The Division Two opinion conflicts with a previous Court of Appeals, *4Division One, opinion interpreting the same statute. We hold that telephone…