State Of Washington v. Joseph Nickols, 47888-9

Inmate Joseph Lee Nickols, at Lewis County Jail, wrote outgoing letters to his girlfriend; jail staff read outgoing mail per policy.
First letter described a jail associate with a .40 pistol and discussed ordering a hit; classification officer Jack Haskins forwarded it to detectives.
Haskins directed jail technician Kari Lupo to send Nickols a "notice of restricted mail" that stated the letter had been turned over to detectives; Lupo signed the notice as "K. Lupo per Ofc. Haskins."
Two days later Nickols attempted to send another letter; folded outward was a large message insulting staff and instructing them to "send that to the DA," and inside included threats to rape and shoot jail staff and references to obtaining a gun after release.
Haskins (who read the letters) testified he felt specifically threatened and feared for himself and his children; Lupo (who did not read the letters but read Haskins' log quoting threatening passages and knew her name appeared on the earlier notice) testified she was fearful and upset.
Jury convicted Nickols of two counts of felony harassment of criminal justice participants (Haskins and Lupo); Nickols appealed arguing insufficient evidence that he specifically threatened those two officers.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether State presented sufficient evidence that Nickols specifically threatened Haskins and Lupo (felony harassment of criminal justice participants)	The State: evidence and reasonable inferences show Nickols intended to communicate threats to staff who interfered with his mail (Haskins and Lupo); victim testimony established fear.	Nickols: threats were general rants not naming victims; State speculated in identifying Haskins and Lupo as targets.	Court affirmed: viewing evidence in State's favor, a rational juror could find Nickols knew he was communicating threats and that those communications conveyed intent to cause bodily harm to the persons threatened (Haskins and Lupo).

State v. Salinas, 119 Wn.2d 192, 829 P.2d 1068 (1992) (standard for reviewing sufficiency of the evidence; all reasonable inferences drawn for the State)
State v. Delmarter, 94 Wn.2d 634, 618 P.2d 99 (1980) (circumstantial and direct evidence are equally reliable)
State v. Camarillo, 115 Wn.2d 60, 794 P.2d 850 (1990) (credibility determinations are for the trier of fact)
State v. J.M., 144 Wn.2d 472, 28 P.3d 720 (2001) (defendant need not directly communicate threat to victim; defendant must subjectively know he is communicating a threat and know the communication conveys intent to cause bodily injury)