State Of Washington v. Laura Marie Beebe, 73812-7

In March 2014, Tony and Connie Brown surrendered Laura Beebe’s Labrador to the Seattle Animal Shelter after asking Beebe to take the dog; Connie notified Beebe and gave the shelter Beebe’s phone number.
The shelter treated the dog as a detained/surrendered animal; after the statutory holding period the dog became eligible for adoption and was adopted by Carmella Patterson on March 27.
Pet microchip company later recorded Patterson as the new owner; Beebe learned of the adoption in late June, confronted Patterson, and took the dog from Patterson’s person in June 2014.
Beebe admitted taking the dog but claimed a good faith claim of title based on online research and belief the dog was hers; she did not consult police or counsel or pursue judicial resolution.
Beebe was charged with first-degree theft; the jury convicted her and the trial court imposed 192 days of community service (alternative). Beebe appealed, arguing insufficient evidence to disprove her good-faith claim of title and that a jury instruction was an improper judicial comment on the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to disprove Beebe’s good-faith claim of title	State: Evidence (notifications, adoption, PetWatch contact, Beebe’s delay and Facebook posts, failure to seek police/court) shows lack of good faith	Beebe: She genuinely believed the dog was hers based on internet research and thought it was abandoned	Held: Sufficient evidence supports that Beebe did not act under a good-faith claim of title; conviction affirmed
Whether jury Instruction 6 (explaining Shelter holding period/authority to permit adoption) was an improper judicial comment on the evidence	State: Instruction correctly states municipal law and does not tell jury ownership was established	Beebe: Instruction impermissibly comments on contested factual question of shelter authority/ownership	Held: Instruction was a correct statement of law, not an improper judicial comment; no reversible error

In re Winship, 397 U.S. 358 (due process requires State to prove every element beyond a reasonable doubt)
Witherspoon, 180 Wn.2d 875 (standard for sufficiency review in Washington)
Salinas, 119 Wn.2d 192 (deference to trier of fact on credibility and inferences)
Thomas, 150 Wn.2d 821 (circumstantial and direct evidence equivalence; credibility deference)
Hicks, 102 Wn.2d 182 (good-faith claim of title defense negates intent; State must disprove beyond reasonable doubt)
Ager, 128 Wn.2d 85 (same principle regarding burden to disprove claim of title)
Lew, 156 Wn.2d 709 (prohibition on judicial comments to jury; review of instructions de novo)
Becker, 132 Wn.2d 54 (example of impermissible judicial comment analysis)
Sinclair, 192 Wn. App. 380 (factors for appellate costs discretion)