State Of Washington v. Karla P. Chavez-montoya, 75172-7

At ~3:00 a.m., Karla Chavez Montoya and an accomplice ("Smiles") shopped at Walmart; Smiles left the store with a cart of unpaid merchandise while Chavez Montoya remained in the store but knew Smiles had not paid.
A Walmart asset protection associate, Ryan Meyer, confronted Smiles outside the store to recover the cart.
A physical altercation ensued: Smiles punched Meyer, and Chavez Montoya joined and struck Meyer in the head multiple times.
Smiles and Chavez Montoya fled in a car; they abandoned the shopping cart, which was later retrieved by staff.
Chavez Montoya was convicted after a bench trial of second-degree robbery as an accomplice; the court imposed several LFOs including a $200 criminal filing fee.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency: whether evidence showed force was used to obtain/retain stolen property	State: a rational trier of fact could infer Smiles used force to retain property when confronted; accomplice liability makes Chavez Montoya responsible	Chavez Montoya: video shows force was used only to escape after abandoning the cart, so it was not force "to obtain or retain" the property	Affirmed — viewing evidence in the light most favorable to the State, a rational trier of fact could infer force was used before abandonment; accomplice liability supports robbery conviction
Criminal filing fee: whether RCW 36.18.020(2)(h) $200 fee is mandatory	State: fee is mandatory under statutory language ("shall be liable")	Chavez Montoya (raised on appeal): fee is discretionary because "liable" can be non-mandatory; trial court intended only mandatory LFOs	Affirmed — statutory text ("shall") indicates the fee is mandatory; court follows recent authority interpreting the provision
Appellate costs: whether to award costs against defendant	State initially sought costs but withdrew in light of defendant's finances	Chavez Montoya requested no appellate costs	Court declined to award appellate costs to the State

State v. Larson, 184 Wn.2d 843 (describes prosecution's burden of proof beyond a reasonable doubt)
State v. Salinas, 119 Wn.2d 192 (standard for reviewing sufficiency of the evidence)
State v. Homan, 181 Wn.2d 102 (bench-trial review: findings for substantial evidence, legal conclusions de novo)
State v. Handburoh, 119 Wn.2d 284 (retention of property via force after an initial peaceful taking constitutes robbery)
State v. Johnson, 155 Wn.2d 609 (force used only to escape after abandoning property does not support robbery)
State v. McIntyre, 112 Wn. App. 478 (shoplifting then pushing security guard upon confrontation supports robbery)
State v. Manchester, 57 Wn. App. 765 (use of force after taking outside owner's presence can constitute robbery)
State v. Gonzales, 198 Wn. App. 151 (interpreting RCW 36.18.020(2)(h) as imposing a mandatory criminal filing fee)