State Of Washington, V. Ricky Anthony Jackson, 85650-2

Ricky Anthony Jackson was convicted by a jury of unlawful possession of a firearm in the first degree and attempting to elude a pursuing police vehicle after an incident in Seattle in 2018.
Jackson, previously in a relationship with the complainant Porsha Lester, was identified by Lester after she called 911, reporting Jackson had threatened her with a pistol and had driven away in a gray Dodge Charger.
Police pursued the Charger, which crashed; surveillance and witness evidence linked Jackson to firearms discarded at the scene and along the pursuit route.
Jackson was located and arrested near the crash, and physical/forensic evidence, as well as multiple witness testimonies, supported the link between Jackson, the vehicle, and the firearms.
The jury convicted Jackson of unlawful possession of a firearm and attempt to elude, but acquitted him on felony harassment/domestic violence; he appealed arguing insufficient evidence and erroneous imposition of a victim penalty assessment (VPA).
The appellate court affirmed the convictions but reversed the imposition of the VPA due to Jackson's indigency and changes in the law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for firearm possession	State presented adequate evidence he possessed firearm(s)	Statute requires proof he knowingly possessed; insufficient evidence	Evidence sufficient; statute does not require knowledge
Sufficiency of evidence for attempt to elude	Ample circumstantial and direct evidence tied him to vehicle	No conclusive proof he was driver during pursuit	Evidence sufficient; jury could reasonably infer identity
Victim Penalty Assessment (VPA)	VPA should not apply due to changes in law and indigency	VPA was imposed at sentencing	VPA must be stricken; remanded to strike from judgment

Jackson v. Virginia, 443 U.S. 307 (1979) (establishes standard for sufficiency of evidence in criminal cases)
State v. Cardenas-Flores, 189 Wn.2d 243 (Wash. 2017) (addresses reviewing sufficiency of evidence and drawing inferences favorably for state)
State v. Stewart, 12 Wn. App. 2d 236 (Wash. Ct. App. 2020) (articulates standard reviewing sufficiency of evidence)
State v. Melland, 9 Wn. App. 2d 786 (Wash. Ct. App. 2019) (confirms sufficiency review is a constitutional matter reviewed de novo)
State v. Smith, 13 Wn. App. 2d 420 (Wash. Ct. App. 2020) (trier of fact decides credibility; appellate courts do not revisit)