State Of Washington v. Tye Glen West, 75465-3

Tye West was arrested and charged with first-degree trafficking in stolen property and residential burglary after police linked jewelry sold by him to items reported missing in a residential burglary.
Detectives Ludwig and Maples located commercial buy/sell records showing West sold the unique stolen jewelry the same day as the burglary and interrogated West about how he obtained the items.
In the interview West first said he traded heroin for the jewelry; detectives told him that explanation “did not make sense,” then told him they believed the items came from a burglary; West changed his story and gave a taped statement implicating accomplices (David and Roshell) and described driving them and later receiving jewelry.
West moved pretrial to exclude detectives’ testimony that they told him his initial story did not make sense as impermissible opinion on credibility under ER 608(a); the court allowed the detectives to testify about what they said to prompt additional statements but barred opinion that West was lying.
At trial the jury convicted West of trafficking in stolen property in the first degree and acquitted him of residential burglary; West appealed arguing (1) improper opinion testimony and (2) insufficiency of evidence that he knowingly trafficked in stolen property.

Issue	Plaintiff's Argument (State)	Defendant's Argument (West)	Held
Admissibility of detectives’ statements in interrogation	Statements showing detectives confronted West were admissible to provide context for why he changed his story	Statements amounted to impermissible opinion on defendant's veracity in violation of ER 608(a)	Testimony was admissible: officers may repeat interrogation statements (e.g., accusing lying) when providing context that explains subsequent statements
Sufficiency of evidence for knowing trafficking	Circumstantial and direct evidence (location, conduct, timing, prior similar conduct, change of story/emotion) support inference West knowingly sold stolen property	State failed to prove West knew the property was stolen; possession alone insufficient	Evidence sufficient: reasonable inferences support knowledge and guilty conscience; conviction affirmed

State v. Demery, 144 Wn.2d 753 (discusses limits on officer testimony about defendant veracity and when statements may be repeated for context)
State v. Kirkman, 159 Wn.2d 918 (admitting interview protocol/context testimony to allow jury to assess responses)
State v. Notaro, 161 Wn. App. 654 (officers may testify they told defendant his story was not credible to explain why he altered his account)
In re Pers. Restraint of Lui, 188 Wn.2d 525 (officers may repeat interrogation statements accusing lying if providing context)
Jackson v. Virginia, 443 U.S. 307 (standard for reviewing sufficiency of the evidence)
State v. Couet, 71 Wn.2d 773 (recent possession of stolen property plus corroborating evidence can support guilt)