State of Washington v. Dennis Wallace Patterson
196 Wash. App. 451
| Wash. Ct. App. | 2016Background
- Dennis Patterson believed county officials and Judge Gina Tveit lacked authority due to alleged defects in oath taking and appeared in Judge Tveit’s courtroom to present a prepared statement.
- On January 5, 2015, Patterson loudly read his statement as the judge entered; the judge said court was in session and ordered audience silence to preserve the record.
- Patterson continued speaking after being told to stop; the judge recessed court and ordered him removed; a deputy arrested and removed him for trespass.
- Other persons subsequently disrupted the docket; interruptions delayed the morning traffic infraction docket about 20 minutes.
- Patterson was convicted by a jury of disorderly conduct (RCW 9A.84.030(1)(b)) and interference with a court (RCW 9.27.015) and appealed, arguing statutory overbreadth and insufficient evidence of intent to disrupt.
Issues
| Issue | Patterson's Argument | State's Argument | Held |
|---|---|---|---|
| Whether RCW 9A.84.030(1)(b) is facially overbroad under the First Amendment and article I, §5 | The statute criminalizes protected speech by prohibiting intentional disruption of meetings | The statute targets substantial disruptions, not protected speech; it can be narrowly construed | The court upheld the statute as not substantially overbroad when read to require an intentional, substantial disruption that reasonably delays or cancels the meeting |
| Proper construction of "disrupt" and "without lawful authority" in RCW 9A.84.030(1)(b) | N/A (argued for broader protection) | The words should be narrowly construed to require substantial interference and lack of specific recognized authority | Court construed "disrupt" to mean substantial disruption (reasonable delay/cancellation) and "without lawful authority" as lacking specific recognized authority |
| Sufficiency of evidence for intent to substantially disrupt (disorderly conduct) | Patterson: he only intended to petition the government, not to disrupt | The State: his continued loud speech after orders and the recess support intent to disrupt | Evidence was sufficient; a rational jury could find Patterson intended to substantially disrupt the proceeding |
| Sufficiency of evidence for interference with a court (RCW 9.27.015) | Patterson: protected petitioning, not interference | State: statute covers demonstrations that impede court administration; his conduct delayed proceedings | Jury conviction affirmed; the court found sufficient evidence to convict for interference as well |
Key Cases Cited
- City of Houston v. Hill, 482 U.S. 451 (recognizes overbreadth analysis and careful scrutiny of statutes affecting speech)
- Colten v. Kentucky, 407 U.S. 104 (upheld narrowly construed disorderly conduct provision addressing disruptions)
- Cox v. Louisiana, 379 U.S. 536 (speech and assembly rights are subject to reasonable time, place, and manner limits to preserve public order)
- State v. Immelt, 173 Wn.2d 1 (discusses overbreadth doctrine and burden in free-speech challenges)
- City of Tacoma v. Luvene, 118 Wn.2d 826 (statute invalid only if no limiting construction is available)