State of Washington v. Lelbert Louise Williams, 33832-1

In May 2014 Leibert Williams was arrested after being observed attempting to pry open a storage unit; police found duffel bags containing items belonging to multiple victims. Williams was charged with several offenses, including second-degree possession of stolen property (value element > $750).
At trial victim Adam Macomber identified items taken from his apartment and testified he could give a "rough estimate" of total loss as "$800." No other evidence of market value (purchase price, condition, or trade value) was introduced.
The jury convicted Williams of second-degree possession of stolen property and several other offenses; he was acquitted of residential burglary. The trial court denied Williams' request for a drug offender sentencing alternative (DOSA), citing no evidence of substance abuse.
Williams appealed the sufficiency of the evidence supporting the value element and challenged the DOSA denial and other procedural matters; he also filed a personal restraint petition raising several claims.
The Court of Appeals reversed the conviction for second-degree possession of stolen property for insufficient evidence on the value element, affirmed denial of DOSA, dismissed the PRP, and remanded for resentencing (vacating the one overturned conviction).

Issue	Plaintiff's Argument (State)	Defendant's Argument (Williams)	Held
Sufficiency of evidence to prove value > $750 for 2nd‑degree possession of stolen property	Macomber's ownership and testimony that loss was "roughly $800" suffices to prove value beyond a reasonable doubt	Macomber's "rough estimate" lacked foundation (market/fair‑market basis, purchase date/price, condition) so State failed to prove value element	Reversed possession conviction: lay "rough" estimate insufficient to prove market value > $750 beyond a reasonable doubt
Trial court denial of DOSA request	Trial court considered DOSA; no requirement to order evaluation absent evidence	Williams argued trial court failed to consider or order evaluation to determine DOSA eligibility	Affirmed: court did not abuse discretion; Williams presented no evidence of substance abuse to support DOSA
Jury instruction on intent for attempted 2nd‑degree burglary	State: instruction on intent was given	Williams: claimed manifest constitutional error for missing intent instruction	Affirmed: record shows intent instruction was given
Personal restraint petition raising multiple claims (Fourth Amendment, Brady, confrontation, perjury, jury bias, late charge)	State: many claims unsupported or unparticularized; no prejudice shown	Williams: alleged multiple trial errors and withheld/impeachment evidence	Denied/dismissed: petitioner failed to show actual prejudice or to identify specific supporting facts

State v. Hammond, 6 Wn. App. 459 (1972) (victim may testify to value of own chattel; weight for jury)
State v. Ehrhardt, 167 Wn. App. 934 (2012) (insufficient evidence where testimony failed to establish current market value)
McCurdy v. Union Pacific R.R., 68 Wn.2d 457 (1966) (owner can testify to market value without expert foundation)
State v. Hermann, 138 Wn. App. 596 (2007) (value may be proved by inference; price paid entitled to weight)
State v. Melrose, 2 Wn. App. 824 (1970) (changes in condition admissible to show value)
State v. Grayson, 154 Wn.2d 333 (2005) (trial court discretion and standards for DOSA relief)
Jackson v. Virginia, 443 U.S. 307 (1979) (standard for sufficiency of the evidence review)