State Of Washington, V Jared Alfons Heminger, 49271-7

Heminger was charged with first-degree trafficking in stolen property and second-degree theft; he entered a drug court contract and, after termination, agreed to a bench trial on stipulated facts.
Stipulated facts showed text messages from a phone labeled “Jared Heminger” offering security equipment for sale priced about $3,500.
Detective investigation revealed the equipment belonged to Jason Cane (employer of Heminger’s father) and Heminger’s father said his son must have taken the items from a work truck.
The trial court found the goods were stolen but concluded the stipulated facts were insufficient to convict Heminger of second-degree theft.
The court nevertheless convicted Heminger of first-degree trafficking in stolen property and sentenced him to nine months.
On appeal Heminger argued the trial court failed to specifically address the statutory element of “knowledge” in its findings and conclusions for the trafficking conviction.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Heminger)	Held
Whether the trial court’s findings sufficiently addressed the knowledge element for first-degree trafficking	Findings need not restate every mental-state word if facts support conviction; any omission is harmless	Findings failed to specifically state the defendant’s knowledge as required by CrR 6.1(d) and Banks	Court: Error to omit specific findings on knowledge, but error was harmless on these facts

State v. Banks, 149 Wn.2d 38 (2003) (bench-trial findings must separately state factual basis for each element)
State v. Brown, 147 Wn.2d 330 (2002) (harmless-error standard for convictions)
State v. Womble, 93 Wn. App. 599 (1999) (possession of recently stolen property plus slight corroboration can prove guilty knowledge)
State v. Powell, 126 Wn.2d 244 (1994) (reasonable-probability test for harmless error)