State Of Washington v. Ronald Allen Ahlquist, 76734-8

Defendant Ronald Ahlquist was tried for manslaughter, theft, and identity theft after his elderly father was found dead from malnutrition and neglect; Ahlquist was his sole caregiver.
Police found the father's body wrapped in an air mattress in a van; the medical examiner attributed death to malnutrition due to dementia and neglect.
Ahlquist admitted not feeding his father for periods and using the father’s debit card tied to social security benefits for personal purchases.
At trial Ahlquist argued he provided the level of care his father wanted and had permission to access benefits.
The jury convicted after roughly four hours of deliberation and found aggravating circumstances; Ahlquist received 110 months’ confinement.
On appeal Ahlquist raised (1) that the jury should have been instructed that all 12 jurors must deliberate together at all times, and (2) that the trial court erred by not entering written CrR 3.5 findings after admitting his statements to police.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury unanimity/deliberation instruction	Ahlquist: Trial court should have instructed jury that deliberations must include all 12 jurors at all times; short deliberation creates reasonable possibility of separated deliberations	State: No objection at trial; standard deliberation instruction was given and no manifest constitutional error shown on this record	Court: Declined to review unpreserved claim because Ahlquist failed to show manifest constitutional error; purely speculative allegations insufficient
CrR 3.5 written findings for admissibility of statements	Ahlquist: Court failed to enter required written findings after CrR 3.5 hearing; requests remand for written findings	State: Concedes error but argues oral findings suffice for appellate review	Court: Error conceded but harmless because oral ruling adequately explains rationale; no remand required

State v. Lamar, 180 Wn.2d 576 (discusses unanimity and prohibition on reconstituting juries without joint deliberation)
State v. Gordon, 172 Wn.2d 671 (defines manifest constitutional error as requiring actual prejudice)
State v. O'Hara, 167 Wn.2d 91 (clarifies standard for obviousness of error on the record)
State v. McFarland, 127 Wn.2d 322 (no manifest error where facts necessary to adjudicate claim are not in the record)
State v. Cunningham, 116 Wn. App. 219 (oral CrR 3.5 findings can be sufficient for appellate review)