State Of Washington, Res. v. Jeffrey S. Sanders, App.

Uj'.'h! Or Afri b iA! L uV i.'AOMiN'G ! C' 20I3OCT2! AH 8=26 IN THE COURT OF APPEALS FOR THE STATE OF WASHINGTON STATE OF WASHINGTON, No. 68771-9-1 Respondent, DIVISION ONE JEFFREY SAUNDERS, PUBLISHED OPINION Appellant FILED: October 21.2013 Spearman, A.C.J. — The purpose of the "essential elements" rule in the context of a to-convict instruction is to ensure that the jury is not left guessing at the meaning of an element of the crime and that the State is not relieved of its burden of proving each element of the crime. By contrast, the goal of the "essential elements" rule in the context of…