State Of Washington v. Deanna Hayes, 48621-1

Owner Eldon Schalk left home Aug 5–12, 2013; on return he found his son and Deanna Hayes living there and had them removed.
On Aug 16 Schalk reported a burglary: a gold nugget charm and long gold necklace were missing; evidence indicated unlawful entry via garage skylight.
Hayes and Schalk’s son were found walking near the residence on Aug 9 and later sold the gold nugget charm to a Portland pawn shop on Aug 26; pawn paperwork showed Hayes’s driver’s license and a signed declaration of ownership.
Video of the specific pawn transaction was unavailable at trial, but officers identified Hayes and Schalk’s son from the recording; the State admitted the pawn declaration and a sample pawn video to demonstrate camera quality.
Hayes was tried on residential burglary, first‑degree trafficking in stolen property, and third‑degree theft; the jury convicted on first‑degree trafficking, hung on the other counts, and the court dismissed the remaining charges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: Did evidence show Hayes knowingly trafficked in stolen property in WA?	State: Hayes lived with and had access to the residence, was seen near it during the relevant time, and pawned the charm—supporting a finding she knowingly trafficked in WA.	Hayes: State failed to prove she knowingly trafficked in stolen property in Washington (pawn occurred in Oregon).	Affirmed — sufficient circumstantial evidence that Hayes constructively possessed the charm in WA with intent to sell and knew it was stolen.
Accomplice liability: Could Hayes be convicted as an accomplice if she didn’t burglarize?	State: Hayes’s intimate involvement with the son, presence at/near the scene, and role in pawning corroborate accomplice liability.	Hayes: Insufficient evidence to establish she aided or agreed to aid trafficking.	Affirmed — evidence supported conviction as an accomplice.
Firearm notification: Did the trial court comply with RCW 9.41.047(1)(a) oral-notification requirement?	N/A (court’s obligation).	Hayes: Trial court failed to orally notify her of the firearm prohibition.	Reversed as to notification — trial court erred; remanded for hearing to provide oral and written firearm prohibition notice.

State v. Kalebaugh, 183 Wn.2d 578 (Wash. 2015) (State must prove every element beyond a reasonable doubt)
State v. Salinas, 119 Wn.2d 192 (Wash. 1992) (sufficiency review and viewing evidence in light most favorable to State)
State v. Delmarter, 94 Wn.2d 634 (Wash. 1980) (circumstantial and direct evidence carry equal weight)
State v. Camarillo, 115 Wn.2d 60 (Wash. 1990) (deference to jury on credibility and conflicting testimony)
State v. Cote, 123 Wn. App. 546 (Wash. Ct. App. 2004) (constructive possession defined as dominion and control)
State v. Spruell, 57 Wn. App. 383 (Wash. Ct. App. 1990) (access and proximity alone insufficient for dominion and control)
State v. Killingsworth, 166 Wn. App. 283 (Wash. Ct. App. 2012) (elements of trafficking in stolen property summarized)
State v. Hermann, 138 Wn. App. 596 (Wash. Ct. App. 2007) (knowingly pawning stolen property supports trafficking charge)