In re Pers. Restraint of Arntsen (Majority)
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The petitioner, Ricky Arntsen, was convicted of several crimes including second degree assault with a deadly weapon following a road rage incident where he forced another driver, Kim Koenig, to stop her car and then circled her vehicle while carrying an AK-47 assault rifle. Arntsen filed a personal restraint petition (PRP) challenging the sufficiency of the evidence for the second degree assault charge. He argued that the State failed to prove that he had the specific intent required for second degree assault, given that the testimony showed he did not point the gun at another person, nor did it establish that Koenig actually experienced apprehension and imminent fear of bodily injury.
The Supreme Court of the State of Washington rejected Arntsen's arguments, ruling that the evidence was sufficient to support the conviction. The court noted that while Arntsen did not point the rifle directly at Koenig, the totality of his conduct, including his aggressive driving and approaching Koenig's car with the rifle after angrily forcing her to stop, provided sufficient basis for a rational trier of fact to infer that he intended to make her fear he might harm her. The court also held that Koenig's testimony that at times during the incident she thought Arntsen was going to shoot or harm her, demonstrated that she experienced actual apprehension and fear of injury. The Supreme Court of the State of Washington therefore reversed the decision of the Court of Appeals and remanded the case back to the Court of Appeals to address the other issues raised in Arntsen’s PRP.
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