City of Seattle v. Evans, 366 P.3d 906

Evans was convicted under Seattle Ordinance SMC 12A.14.080(B) for carrying a fixed-blade knife.
Officer retrieved Evans’s knife from his front pocket after a traffic stop for speeding and smelled marijuana.
Trial evidence included a description of the knife as fixed-blade with a black handle and a plastic sheath; witnesses likened it to a kitchen or paring knife.
Jury instructions defined a dangerous knife as a fixed-blade knife (blade >3.5 inches) or other listed weapons; Evans challenged these as-applied under constitutional rights.
Montana held fixed-blade paring knives are not arms under Article I, §24 of the Washington Constitution; Evans urged reconsideration post-Heller.
The majority affirming Court of Appeals held Evans’s paring knife is not a constitutionally protected arm; Evans’s as-applied challenge fails.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Evans’s paring knife a protected 'arm'?	Evans argues Montana should be reconsidered to include paring knives as arms.	City contends paring knife is not an arm under state or federal law.	Paring knife not an arm; SMC applies.
Does Heller require abrogating Montana or redefining 'arms' for Washington?	Heller supports broader protection of fixed-blade knives as arms.	Heller does not compel a different outcome; Montana framework remains valid.	Montana framework retained; no abrogation.
Does SMC 12A.14.080 operate constitutionally as applied to Evans?	Knife for self-defense should be protected, so the statute as applied violates the Second Amendment.	Even if Evans’s knife were an arm, the statute is a valid, narrowly tailored regulation.	Evans’s knife is not a protected arm; statute constitutional as applied.

Heller v. District of Columbia, 554 U.S. 570 (U.S. Supreme Court 2008) (defined arms and protected core of Second Amendment)
Montana v. City of Seattle, 129 Wn.2d 583 (Wash. 1996) (knives not necessarily arms; framework for arms protection under WA Const)
DeCiccio v. Connecticut, 315 Conn. 79 (Conn. 2014) (dirk knife as arm under Second Amendment; historical analysis)
Delgado v. Oregon, 298 Or. 395 (Or. 1984) (historical use and function of blades in determining arms)
Kessler v. Oregon, 289 Or. 359 (Or. 1980) (definition framework for arms in state constitution analysis)
Peruta v. County of San Diego, 742 F.3d 1144 (9th Cir. 2014) (scope of Second Amendment outside home; burden and scrutiny framework)
McDonald v. City of Chicago, 561 U.S. 742 (U.S. Supreme Court 2010) (incorporation of Second Amendment against the states)
State v. Sieyes, 168 Wn.2d 276 (Wash. 2010) (state constitutional right to bear arms; framework for analysis)
Jorgenson v. State, 179 Wn.2d 145 (Wash. 2013) (means-end scrutiny approach to Second Amendment context)