State v. France

¶1 William Neal France was convicted of five counts of felony harassment and one count of witness intimidation for making multiple harassing calls to his former attorneys. Consistent with the pattern jury instructions on witness intimidation, the jury was instructed that “[a]s used in these instructions, threat also means to communicate, directly or indirectly, the intent immediately to use force against any person who is present at the time.” Clerk’s Papers (CP) at 40 (Instruction 9) (emphasis added); see 11 Washington Practice: Washington Pattern Jury Instructions: Criminal 2.24, at 71-72…