State v. Villanueva-Gonzalez, 180 Wash. 2d 975

Villanueva-Gonzalez was convicted of second degree assault and fourth degree assault for a domestic violence incident against his girlfriend.
The two convictions arose from a single domestic incident in which he head-butted the victim and later grabbed her neck and restrained her.
There was no statutory definition of assault; common-law definition was ambiguous, prompting guidance from other jurisdictions.
The State included fourth degree assault as a lesser included charge on both second degree assault counts.
The Court of Appeals reversed one conviction; the Supreme Court reviewed whether the pair violated double jeopardy and concluded they did.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did convictions violate double jeopardy?	Villanueva-Gonzalez contends two convictions punish the same offense.	State contends unit of prosecution supports multiple offenses under assault.	Yes; assault is a course of conduct, so convictions violate double jeopardy.

Blockburger v. United States, 284 U.S. 299 (1932) (establishes the test for same offense and unit of prosecution)
State v. Adel, 136 Wn.2d 629 (1998) (statutory ambiguity and lenity guide interpretation)
State v. Roberts, 117 Wn.2d 576 (1991) (rule of lenity applied in double jeopardy context)
State v. Hughes, 166 Wn.2d 675 (2009) (de novo review of double jeopardy claims in WA)