State Of Washington v. Christopher Thomas Ackley, 74062-8

Ackley confronted James O'Connor in a neighborhood after prior petty harassment (firecrackers, egging) and verbal provocation; Ackley yelled at O'Connor, blocked the street, and exited his car.
Ackley testified he briefly opened a pocketknife and held it down by his side because he believed O'Connor might pull a gun after O'Connor pulled up his shirt; he then closed the knife, tossed it onto the driver’s seat, and left.
O'Connor testified Ackley produced and waved a knife, threatened to "slice you open," and advanced toward him, after which Ackley returned to his car and drove off.
Police investigated; Ackley sought to admit prior threatening text messages from O'Connor and requested jury instructions on self-defense; the trial court reserved ruling on the message and denied the self-defense instruction.
The jury convicted Ackley of second-degree assault with a deadly weapon; on appeal the court reviewed de novo whether the evidence was sufficient to require a self-defense instruction.

Issue	Plaintiff's Argument (Ackley)	Defendant's Argument (State)	Held
Whether trial court erred by refusing a self-defense jury instruction	Ackley argued his testimony showed a subjective belief of imminent danger (O'Connor pulling his shirt + prior threats + L.A. experience) and thus raised self-defense	State argued record lacked evidence that Ackley subjectively believed he needed to use otherwise unlawful force; holding knife at side was not an unlawful use of force	Court held no error: insufficient evidence of subjective belief that unlawful force was necessary; no self-defense instruction required
Whether the court erred in excluding prior threatening messages from O'Connor	Ackley argued messages were relevant to his state of mind and reasonable fear	State argued admission depended on a viable self-defense theory and, absent that, messages were irrelevant	Court held exclusion was proper because once self-defense lacked an essential element, prior-threat evidence was irrelevant

State v. Aleshire, 89 Wn.2d 67 (1977) (one cannot deny striking someone and simultaneously claim self-defense)
State v. Walker, 136 Wn.2d 767 (1998) (standards for self-defense instruction and review)
State v. Read, 147 Wn.2d 238 (2002) (elements required to obtain a self-defense instruction)
State v. Callahan, 87 Wn. App. 925 (1997) (evidence standard for inconsistent defenses and self-defense sufficiency)
State v. Werner, 170 Wn.2d 333 (2010) (defenses may be inconsistent if supported by evidence)
Holmes v. South Carolina, 547 U.S. 319 (2006) (defendant entitled to present a complete defense)
State v. Wanrow, 88 Wn.2d 221 (1977) (prior threats may be relevant to self-defense claim)