State v. Williams

¶1

Madsen, J.

Matthew Williams challenges his conviction for possession of an unlawful firearm pursuant to RCW 9.41.190. Williams claims that instruction 11, the “to convict” instruction, was a misstatement of the law because it failed to inform the jury that in order to convict him, it must find he knew the characteristics of the firearm that made it unlawful under RCW 9.41.190. We hold the State must prove that a defendant knows, or should know, the characteristics of the firearm that make it unlawful.

¶2 Nevertheless, we conclude that the defect in instruction 11 was harmless. There is no…