State v. Simmons

— Jeffrey Rosander Simmons appeals his forgery conviction, arguing that there was insufficient evidence of “intent to injure” and, therefore, it was reversible error to have charged alternative means of committing the forgery. We hold that, within the context of this case, intent to injure and intent to defraud are not alternative means but, rather, describe the same facts and mental state, sufficient to support the conviction. We affirm.

FACTS

Simmons was detained in the Forks Jail, Clallam County. While in the booking area, he noticed that another man being booked had ripped up a 20-dollar…