State Of Washington v. Michael William Richie

¶ 1 — Michael Richie appeals his conviction for first degree robbery. He argues that an implied element of the crime of robbery based on taking property in the presence of a person is that the person have an ownership interest in, a representative interest in, or possession of the property stolen. As a result, he argues that there was insufficient evidence to support a first degree robbery conviction because the State failed to prove this element and that the to-convict jury instruction relieved the State of its burden of proving this element.

¶2 We hold that (1) an essential element of first…