State of Washington v. Joshua Michael Barnes
196 Wash. App. 261
| Wash. Ct. App. | 2016Background
- On June 22, 2015, Joshua Barnes took (without permission) Judy Fraker's gas-powered, self-propelled riding lawnmower and placed it in the bed of a pickup; he later admitted attempting to steal it.
- The State charged Barnes with theft of a motor vehicle (RCW 9A.56.065), among other offenses; Barnes moved to dismiss that count pretrial under Knapstad.
- The trial court granted dismissal of the motor-vehicle-theft charge, concluding a riding lawnmower is not a "motor vehicle" for purposes of RCW 9A.56.065.
- The State appealed; the primary legal question is statutory construction: whether a riding lawnmower falls within the statutory term "motor vehicle" when read alongside Title 46 definitions and the purposes of the motor-vehicle-theft statute.
- Title 46 defines "motor vehicle" as every self-propelled vehicle and Title 9A directs courts to interpret criminal statutes to effect legislative purpose and proportionality.
- The court balanced a literal reading of Title 46 (which could encompass lawnmowers) against the 2007 legislative findings behind RCW 9A.56.065 (focused on automobiles and auto-theft harms) and precedent favoring purposive construction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a riding lawnmower is a "motor vehicle" under RCW 9A.56.065 | The State: Title 46's broad definitions ("every" self-propelled vehicle) plainly include riding lawnmowers; no exclusion exists, so plain meaning controls | Barnes: A purposive reading excludes lawnmowers because RCW 9A.56.065 targets automobile thefts, and literal inclusion would produce absurd, disproportionate results | Court affirmed dismissal: riding lawnmower is not a "motor vehicle" for the theft statute; legislative purpose and proportionality override a strictly literal Title 46 reading |
Key Cases Cited
- State v. Knapstad, 107 Wn.2d 346 (1986) (pretrial dismissal standard when undisputed facts cannot support conviction)
- State v. Day, 96 Wn.2d 646 (1981) (statute construed in light of its purpose; avoided literal result that would defeat legislative objective)
- State v. Montano, 169 Wn.2d 872 (2010) (defendant may bring pretrial motion to dismiss charging document)
- State v. Conte, 159 Wn.2d 797 (2007) (de novo review of Knapstad dismissal)
- Peterson v. King County, 199 Wash. 106 (1939) (construction of "motor vehicle" in earlier statutory context)
- Harris v. State, 286 Ga. 245 (2009) (holding a riding lawnmower not a "motor vehicle" for motor-vehicle-theft statute based on statutory purpose and escape-risk rationale)
- Deere & Co. v. Ford, 434 Mass. 223 (2001) (statutory purpose can limit literal definition of "motor vehicle")