State v. Hall

A jury convicted William Hall of second degree incest for molesting his 16-year-old daughter. *166On appeal, Hall claims that because he had relinquished his parental rights when his daughter was five years old, she was not a descendant for purposes of the incest statute, RCW 9A.64.020. He also argues that his knowledge of his daughter’s adoption negates the mens rea necessary to prove incest.

In this case of first impression, we hold that the biological relationship survives relinquishment of parental rights and that adoption is not a defense to a charge of incest between a biological parent and…