State v. Ferro

William E. Ferro appeals his conviction for public indecency. He claims that under State v. Leach, 113 Wn.2d 679, 782 P.2d 552 (1989), the complaint filed against him was constitutionally deficient. We agree and reverse.

On January 13, 1987, a deputy prosecuting attorney for Ring County signed a form of citation charging Ferro with violation of "RCW 9A.88.010 public indecency".1 In the space on the form provided for "Description", the notation "(See notes)" appears. The citation states the date of the violation as January 10, 1987. There is no indication on the citation that the "notes" were…