Today's two per curiam opinions
State v. Brown, No. 84083-1. Maurice Brown was granted a 72-hour furlough from the Benton County Jail to attend a drug treatment program. He failed to return,and was arrested, charged, and convicted of escape. On appeal, Brown challenged that the charging information had not alleged that he acted knowingly. The Court of Appeals found that the information had failed to allege knowledge, an essential element of the crime, but held also that Brown was not prejudiced and thus upheld the conviction.
In a per curiam opinion the Supreme Court today overturns the Court of Appeals. "Because the information did not adequately apprise Brown of the elements of the crime, the charge must be dismissed without prejudice."
State v. Willingham, No. 84036-9. Jesse Willingham was charged with indecent liberties with a child. The crime has a three-year statute of limitations. Prosecutors argued and the Court of Appeals agreed that the statute of limitations was tolled for a two-week period when Willingham was in Utah for job training. Today, in another per curiam reversal of the Court of Appeals, the Supreme Court holds that the temporary absence from Washington for job training did not toll the statute of limitations.
