State v. Pauling

A statute that defines the word “threat” to include the communication of information that is not inherently wrong or unlawful sweeps too broadly to withstand constitutional challenge. Washington’s extortion statute is overbroad because it is not limited to wrongful threats and does not include any defenses that would limit its reach. Thus, it substantially burdens a wide range of protected speech. Therefore, we are compelled to declare the statute invalid and reverse the conviction in this case.

*447FACTS

Molotov Pauling and his girl friend Jane Doe began a relationship in Washington and moved to…