State Of Washington v. Michael Joseph Wages
48953-8
| Wash. Ct. App. | Mar 14, 2017Background
- On March 25, 2014 Brian Waddle reported his pickup truck stolen; only he and his ex‑wife had keys and had given no one permission to use it.
- On April 11, 2014 Detective Whitley served a warrant at Leonard Fonda’s home, saw a truck matching Waddle’s description, and found Michael Wages hiding in a closet; Fonda told the detective he had seen Wages driving the truck.
- The truck displayed swapped license plates, the public VIN was obscured with cardboard, the ignition had been removed, and the passenger door lock was visibly damaged.
- Inside the truck officers found a prescription pill bottle with Wages’s name, a lighter with his fingerprints, and several fingerprints matching Wages on exterior and interior parts of the truck; a tool modified to remove ignitions was also found.
- A VIN check confirmed the truck belonged to Waddle; the vehicle was impounded and fingerprinted; Wages was charged and a jury convicted him of unlawful possession of a stolen vehicle.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence that Wages possessed the stolen vehicle | State: fingerprints, eyewitness (Fonda), personal items in truck, and presence at Fonda’s house show possession | Wages: evidence insufficient to prove he possessed the truck | Affirmed — sufficient evidence of possession |
| Sufficiency of evidence that Wages knew the vehicle was stolen | State: switched plates, obscured VIN, removed ignition and damaged lock indicate knowledge; actions (VIN covered) show awareness | Wages: insufficient proof he knew the truck was stolen | Affirmed — sufficient circumstantial evidence of knowledge |
| Whether appellate costs should be waived | State: costs may be imposed consistent with cost bill; neither party substantially prevailed | Wages: indigent; requests waiver of appellate costs | Court declined to decide waiver here; left ability‑to‑pay to court commissioner under RAP 14.2 |
Key Cases Cited
- State v. Longshore, 141 Wn.2d 414 (evidence sufficient if any rational trier of fact could find elements beyond a reasonable doubt)
- State v. Homan, 181 Wn.2d 102 (in sufficiency review, defendant admits truth of State’s evidence and reasonable inferences)
- State v. Andy, 182 Wn.2d 294 (deferring to jury on credibility and conflicting testimony)
- State v. Varga, 151 Wn.2d 179 (circumstantial evidence equals direct evidence in weight)
- State v. McPhee, 156 Wn. App. 44 (mere possession of stolen property insufficient; possession coupled with other incriminating evidence can support conviction)
