State v. Williams, 251 P.3d 877

Williams drove away from a Les Schwab dealership without paying for tires and wheels.
He admitted driving away but gave his brother's name instead of his own to avoid an outstanding warrant.
Police located Williams at his girlfriend's home and arrested him after discovery of his true identity.
Williams was convicted of first degree theft, obstructing a law enforcement officer, and making a false or misleading statement to a public servant.
On appeal, the Court of Appeals affirmed the obstruction conviction, but this Court reverses, holding obstruction requires conduct in addition to false statements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does RCW 9A.76.020(1) require conduct beyond making a false statement to convict?	Williams argues false statements suffice for obstruction.	State argues obstruction focuses on willful hindrance, delays, or obstruction regardless of content.	Obstruction requires conduct in addition to false statements; vacate conviction.

State v. White, 97 Wash.2d 92 (1982) (unconstitutional for vagueness; stop-and-identify concerns under article I, section 7)
State v. Grant, 89 Wash.2d 678 (1978) (conduct-focused analysis; prior ruling on obstructing statute via conduct)
City of Mountlake Terrace v. Stone, 6 Wash.App. 161 (1971) (obstruction statute void for vagueness when speech-only demands exceed constitutional bounds)
State v. Williamson, 84 Wash.App. 37 (1996) (held hindering/delay/obstructs applies to conduct, not speech; false statements belong to separate prong)
State v. Hoffman, 35 Wash.App. 13 (1983) (recognizes conduct-based obstruction interpretation)
State v. Swaite, 33 Wash.App. 477 (1982) (precedent supporting conduct requirement for obstruction)