State Of Washington v. C.m.f., Dob: 8/26/00, 75291-0

On Jan. 4, 2016, juveniles C.F. and A.F. rode a bus to Mount Vernon; a confrontation erupted with Devin Belwood and Matthew Wilkerson after exiting the bus.
Surveillance and testimony showed A.F. "made the first move" and exchanged punches with Belwood; Wilkerson restrained A.F. while C.F. struck Wilkerson and later "blindsided" him.
Shortly after C.F. struck Wilkerson, A.F. stabbed Wilkerson in the chest with a knife-like/deadly weapon; Wilkerson required surgery and hospitalization.
The juvenile court found A.F. committed first degree assault (deadly weapon, intent to inflict great bodily harm) and found C.F. was an accomplice who knew the assault would occur, encouraged it, and actively participated.
The court denied any valid self-defense or defense-of-another claim, concluding A.F. was the first aggressor and C.F. had no need to defend when he blindsided Wilkerson.
C.F. appealed, arguing (1) the trial court’s written findings failed to state ultimate facts for each element (JuCR 7.11(d)) and (2) the evidence was insufficient to prove accomplice liability/knowledge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Adequacy of juvenile court findings under JuCR 7.11(d)	Findings insufficiently state ultimate facts for each element	Findings are inadequate and require remand	Court: findings sufficiently state ultimate facts for first-degree assault and accomplice liability; no remand required
Self-defense / unlawfulness of force	N/A (State)	C.F. argues some findings suggest he may have reasonably believed he was defending	Court: even if initial defense plausible, ultimate findings state there was "no need to defend" when C.F. blindsided Wilkerson; self-defense disallowed because A.F. was first aggressor and C.F. was accomplice
Accomplice liability — proof C.F. knew assault would occur	N/A (State)	C.F. contends insufficient evidence he knew his conduct would promote an assault	Court: circumstantial evidence (stepping toward Belwood, verbal provocation, joining strikes, blindsiding Wilkerson) supports that a rational factfinder could conclude C.F. knew an assault would occur
Knowledge of deadly weapon required for accomplice liability	N/A (State)	C.F. argues State had to prove he knew A.F. was armed	Court: not required — accomplice need only know generally he was facilitating an assault; no specific knowledge that principal was armed or would use deadly force required

State v. Alvarez, 128 Wn.2d 1 (1995) (JuCR 7.11(d) findings requirement and remand principle)
State v. Riley, 137 Wn.2d 904 (1999) (first aggressor and withdrawal rule for self-defense)
State v. McDonald, 138 Wn.2d 680 (1999) (defense-of-another and accomplice culpability principles)
State v. Joy, 121 Wn.2d 333 (1993) (standard for reviewing sufficiency of the evidence)
State v. Salinas, 119 Wn.2d 192 (1992) (review standards and inferences drawn for sufficiency challenges)
State v. Bernardy, 25 Wn. App. 146 (1980) (first aggressor/self-defense discussion)
In re Personal Restraint of Sarausad, 109 Wn. App. 824 (2001) (accomplice liability requires general awareness of facilitating an assault, not knowledge of deadly weapon)