State Of Washington, V. I.s., 82559-3

Everett police responded to 911 calls about a domestic violence incident and were directed to unit 52, where yelling was heard and a witness had shown a short fight video.
Officers announced and entered after I.J.S.’s mother opened the door and loudly said her son had been assaulted; officers separated mother and son.
Officers asked I.J.S. to sit; he became noncompliant, attempted to go toward his mother, resisted, and a struggle culminated with officers forcing him to the ground and handcuffing him.
While being restrained, officers allege I.J.S. pulled them to the ground, continued to fight, used racial epithets, and prepared to spit at Sgt. Fairchild (the spit missed); mother shouted that this was an assault on an officer.
I.J.S. was charged with third-degree assault (assaulting a law enforcement officer), moved to suppress evidence as fruits of a warrantless entry, and was convicted after a stipulated-facts bench trial based on police reports.
On appeal I.J.S. challenged (1) sufficiency of the evidence and (2) the denial of his suppression motion; the Court of Appeals applied the Jackson standard for sufficiency, rejected the suppression claim, and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence to convict of third-degree assault (assault on officer)	I.J.S.: Spitting attempt missed, so evidence insufficient to prove assault.	State: Substantial evidence shows intentional offensive contact and resistance — he pulled officers to the ground and fought; a rational trier could find assault.	Affirmed — viewing evidence in the light most favorable to the State, any rational trier of fact could find elements proved beyond a reasonable doubt.
Motion to suppress evidence from warrantless entry	I.J.S.: Entry was unlawful, so subsequent evidence should be suppressed.	State: Even if entry unlawful, evidence of the juvenile's assault on officers is not subject to exclusion as it is not the fruit of the illegality and officers were identifiable and acting in good faith.	Affirmed — assault evidence admissible; court need not resolve exigent-circumstances issue.
Standard of appellate review for bench-trial sufficiency claims	I.J.S.: Relied on Homan formulation limiting review to findings supported by substantial evidence.	State/Court: Applies Jackson v. Virginia — review asks whether any rational trier of fact could find guilt beyond a reasonable doubt; Homan’s narrower approach is inconsistent with federal precedent and prior state precedent.	Court applies Jackson standard (any rational trier of fact; consider all evidence in light most favorable to prosecution).

Jackson v. Virginia, 443 U.S. 307 (1979) (federal standard for sufficiency review: whether any rational trier of fact could find guilt beyond a reasonable doubt)
State v. Green, 94 Wn.2d 216 (1980) (Washington adoption of Jackson standard)
State v. Homan, 181 Wn.2d 102 (2014) (discussed and distinguished regarding bench-trial sufficiency review)
State v. Salinas, 119 Wn.2d 192 (1992) (applied Jackson standard to bench trial)
State v. Stevens, 158 Wn.2d 304 (2006) (common-law definitions of assault)
State v. Cardena-Flores, 189 Wn.2d 243 (2017) (assault by offensive touching battery definition)
State v. Mierz, 127 Wn.2d 460 (1995) (exclusionary rule does not bar admission of evidence of assaults on officers where officers are identifiable and acting in good faith)
Wong Sun v. United States, 371 U.S. 471 (1963) (exclusionary rule limited to fruits of unlawful searches or seizures)
State v. Valentine, 132 Wn.2d 1 (1997) (discussed re: resistance to unlawful police conduct; court noted but declined to revisit its viability)