State v. Valdiglesias LaValle, 535 P.3d 856

Vanessa Valdiglesias LaValle, a mother with prior domestic-violence history, was recorded by her 10-year-old son during a 2020 visit saying she would teach him to poison his father and that if he did so they could be "together forever."
The State charged her with solicitation to commit first‑degree murder and first‑degree assault under RCW 9A.28.030(1) (criminal solicitation: offering "money or other thing of value" to induce criminal conduct).
Trial court denied her pretrial Knapstad dismissal motion and a suppression motion for the recording; at trial the jury convicted her of solicitation to commit first‑degree murder (the assault count was vacated).
The Court of Appeals reversed, holding that "thing of value" in the solicitation statute requires a monetary or marketable item and that a mother’s promise of being together "forever" is not a thing of monetary value.
The Washington Supreme Court granted review and reversed the Court of Appeals, holding the phrase "money or other thing of value" unambiguously includes nonmonetary intangibles (e.g., companionship, care, protection) and remanded for further proceedings consistent with that holding.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Valdiglesias LaValle)	Held
Whether "money or other thing of value" in RCW 9A.28.030(1) is limited to items with monetary/market value	The phrase can encompass nonmonetary items; a promise of being together can constitute a "thing of value."	"Other thing of value" requires monetary/marketable value; a promise of care is not a thing of monetary value.	The phrase is unambiguous and includes nonmonetary intangibles—not limited to marketable items.
Whether a mother’s promise to be "together forever" is a "thing of value" supporting solicitation	The promise has subjective value and can induce criminal conduct; thus it qualifies.	The promise lacks monetary value and so cannot satisfy the statutory element.	The court said a mother’s promise of care falls within "other thing of value" and can support solicitation.

State v. Jensen, 164 Wn.2d 943 (explaining solicitation criminalizes enticement to commit a crime)
Dept. of Ecology v. Campbell & Gwinn, LLC, 146 Wn.2d 1 (plain‑meaning statutory interpretation principles)
State v. Haggard, 195 Wn.2d 544 (text, context, and related provisions guide plain meaning analysis)
State v. Lilyblad, 163 Wn.2d 1 (read statutory terms in context, not isolation)
State v. Costich, 152 Wn.2d 463 (presumption that legislature says what it means)
United States v. Zouras, 497 F.2d 1115 (nonmonetary silence/extortion can be a "thing of value")
United States v. Douglas, 634 F.3d 852 (nonmonetary demands can constitute a "thing of value")
United States v. Girard, 601 F.2d 69 (intangible information can be a "thing of value")