State v. Allen

*127¶1 Joel Allen walked into three Seattle buildings that were partially open to the public, intruded into private areas, and took items belonging to employees. A jury found Allen guilty of burglary, theft, and possession of stolen property. On appeal, Allen contends, among other things, that his right to a unanimous jury was violated because the State did not present sufficient evidence to establish both the “entered unlawfully” and “remained unlawfully” means of committing burglary.

Ellington, A.C.J. —

¶2 Under certain circumstances, the distinction between entering and remaining unlawfully may…