State Of Washington v. Eric Michael Sharpe, 73618-3

Owner Leo Lund died in 2011; his daughter Bonnie Heaven and sisters were clearing his Renton house and kept it locked when not visiting.
On May 31, 2013, neighbor Kathleen Ness heard someone trying to start Lund’s pickup (whose key was kept inside the house) and saw a man rummaging in the yard; she called police.
Deputies found a recently cut bedroom window screen and a path from that window into the woods; a K-9 followed the path and located Eric Sharpe ~200 feet away.
Sharpe was wearing gloves, had glass cutters, pruning shears, and a ring of filed keys; Ness later identified him as the man in the yard.
A week later Heaven found a partially filled suitcase with Lund’s items in the bedroom with the cut screen; the State charged Sharpe with residential burglary and a jury convicted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that defendant intended to commit a crime inside a dwelling (residential burglary)	State: Circumstantial evidence (cut screen, path, suitcase of stolen items, tools on Sharpe, attempts to start truck) permits a jury to infer intent to steal property	Sharpe: Evidence is insufficient to prove intent to commit a crime inside the dwelling beyond a reasonable doubt	Affirmed: Viewing evidence in the light most favorable to the State, a rational jury could infer intent beyond a reasonable doubt

State v. Larson, 184 Wn.2d 843 (2015) (State must prove each element beyond a reasonable doubt)
State v. Salinas, 119 Wn.2d 192 (1992) (standard for reviewing sufficiency of evidence; view evidence in light most favorable to the State)
State v. Lewis, 69 Wn.2d 120 (1966) (intent may be inferred from surrounding facts and circumstances)
State v. Bergeron, 105 Wn.2d 1 (1985) (intent can be inferred when conduct indicates intent as a matter of logical probability)