State v. Williams, 171 Wash. 2d 474

Williams attempted to pay a Les Schwab bill with a check; verification rejected, and he agreed to return with money leaving the Jeep keys with staff.
The Jeep Cherokee was later found missing; police located Williams at his girlfriend’s residence and he admitted driving away without paying.
When asked for identification, Williams gave his brother’s name, raising questions about his true identity.
Booking revealed Williams’s true name and an outstanding warrant; he was charged with first degree theft, obstructing an officer, and making a false/misleading statement.
Court of Appeals affirmed the obstruction conviction; Supreme Court held obstruction must involve conduct beyond making false statements.
Legislative history shows RCW 9A.76.020(1) focused on conduct, while RCW 9A.76.175 targets false/misleading statements to a public servant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether obstruction requires conduct beyond speech	Williams argues obstruction can be satisfied by false statements alone.	State argues plain text allows speech-based obstruction with same language as prior conduct-focused statutes.	Obstruction requires conduct in addition to false statements
Whether Williams' false statements alone support obstruction under the current law	False name to police is sufficient to obstruct under RCW 9A.76.020(1).	Only conduct, not false statements, may support obstruction; separate false-statement statute addresses that conduct.	False statements alone do not sustain obstruction conviction

State v. White, 97 Wn.2d 92 (1982) (held former obstruction subsections unconstitutional for vagueness and privacy concerns)
State v. Grant, 89 Wn.2d 678 (1978) (conduct-based obstruction upheld after distinguishing from speech)
City of Mountlake Terrace v. Stone, 6 Wn. App. 161 (1971) (early rule requiring conduct, not speech, to sustain obstruction)
State v. Williamson, 84 Wn. App. 37 (1996) (false-name alone insufficient; obstruction requires conduct)
State v. Swaite, 33 Wn. App. 477 (1982) (reiterated conduct-focused obstruction interpretation)