State v. Sweany, 281 P.3d 305

2009 fire damaged the Sweanys' trailer; the State charged Leysa and Leah with first-degree arson by alternative means under RCW 9A.48.020(l)(b) (damages a dwelling) and (l)(d) (on property valued at $10,000+ with intent to collect insurance proceeds).
The value issue focused on whether “property valued at ten thousand dollars or more” means market value or insured value; the statute does not define “valued at.”
Evidence at trial on value varied: 2001 asking price $15,000, sale for $10,500 in 2001, Leysa testified the trailer might be worth slightly more than $10,000, community manager testified pre-1995 trailers sell for $6,000–$12,000, and the county assessor valued the property at $8,350.
2008 assessor value ($8,350) and trailer’s poor interior contrasted with other testimony suggesting market value ≥ $10,000.
Court of Appeals affirmed; Supreme Court granted review to resolve the interpretation of RCW 9A.48.020(l)(d) and sufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is ‘property valued at’ market value or insured value under RCW 9A.48.020(l)(d)	Sweanys argue value equals insured value	State argues value is insured value	Value is market value
Is there sufficient evidence to prove market value ≥ $10,000	State asserts evidence supports ≥ $10,000	Sweanys contend evidence fails to prove ≥ $10,000	Yes, sufficient evidence supports market value ≥ $10,000

Holden v. Farmers Ins. Co. of Wash., 169 Wn.2d 750 (Wash. 2010) (defines fair market value framework for valuation evidence)
State v. Randhawa, 133 Wn.2d 67 (Wash. 1997) (sufficiency review for alternative means crimes)
State v. Kintz, 169 Wn.2d 537 (Wash. 2010) (standard for sufficiency in alternative means arson cases)
State v. Lee, 128 Wn.2d 151 (Wash. 1995) (sufficiency review guidance)
State v. Halgren, 156 Wn.2d 795 (Wash. 2006) (sufficiency standard of review for evidence-based challenges)