State of Washington v. Shawn Alan Stahlman, 34375-8

Around 2:00 a.m. on Sept. 23, 2015, Gary Oliver awakened to see Shawn Stahlman near the door of his detached shop; a motion light revealed Stahlman within ~3 feet reaching for the door. Stahlman fled when confronted. He had earlier loaded a wheel and tire from Oliver's property into a white minivan driven by Amy Murphy.
Oliver pursued the minivan in his truck at high speeds (~80–90 mph). While driving, Stahlman gestured and Murphy then veered the van into Oliver’s truck with substantial force. The court found Murphy acted at Stahlman’s command.
At a later stop, Stahlman exited the minivan holding a sledgehammer, ran at Oliver and struck the truck’s fender, denting it.
Stahlman was tried to the bench (Murphy to a jury). The court found Oliver credible and both defendants not credible, convicting Stahlman of attempted second-degree burglary, third-degree theft, third-degree possession of stolen property (lesser included), and two counts of second-degree assault.
The court treated the sledgehammer as a deadly weapon. Sentences for all convictions ran concurrently; Stahlman appealed, challenging sufficiency of evidence for burglary and assaults and arguing he could not be convicted of both theft and possession of the same stolen wheel and tire.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for attempted burglary	State: Stahlman reached for shop door after stealing wheel, took substantial step toward burglary	Stahlman: No entry or touching of door; insufficient evidence of intent/attempt	Court: Evidence (reaching for door after prior theft, flight) supported attempted burglary conviction
Sufficiency of evidence for assault by vehicle	State: High-speed ramming placed Oliver in reasonable fear of substantial harm	Stahlman: He acted in self-defense; Oliver was the aggressor	Court: Trial judge discredited self-defense; vehicle assault supported as assault with deadly weapon
Sufficiency of evidence for assault with sledgehammer	State: Exiting with sledgehammer and swinging created apprehension/substantial harm	Stahlman: Action was self-defense or justified	Court: Judge rejected self-defense; sledgehammer qualified as deadly weapon; assault conviction supported
Double convictions for theft and possession of same property	State: Charged both offenses arising from taking and possessing wheel/tire	Stahlman: Cannot be both principal thief and receiver/possessor of same item	Court: Agreed — may not convict for both; possession conviction reversed/stricken; theft conviction stands

State v. Green, 94 Wn.2d 216 (discusses appellate standard for sufficiency review)
Jackson v. Virginia, 443 U.S. 307 (established constitutional sufficiency standard)
State v. Camarillo, 115 Wn.2d 60 (appellate deference to factfinder credibility determinations)
State v. L.B., 132 Wn. App. 948 (burden on State to disprove self-defense beyond reasonable doubt)
State v. Mullin-Coston, 152 Wn.2d 107 (accomplice liability: accomplice may be convicted even if principal is acquitted)
State v. Melick, 131 Wn. App. 835 (holding that theft and possession arising from same act cannot both stand)
State v. Hancock, 44 Wn. App. 297 (same principle: cannot be both principal thief and possessor of same stolen property)