State Of Washington v. Koran Butler

¶1 — Koran Butler appeals his convictions and sentence for forgery, second degree identity theft, and attempted second degree theft. He primarily argues that the trial court violated his constitutional right to a unanimous verdict by not issuing a unanimity instruction because the State provided insufficient evidence of one of the alternative means of committing identity theft. In the published portion of this opinion, we hold that identity theft is not an alternative means crime. In the unpublished portion of this opinion, we consider and reject Butler’s arguments regarding the trial court’s…