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State v. Rockwell
Citations: 544 P.2d 1250; 86 Wash. 2d 393; 1976 Wash. LEXIS 864Docket: 43667
Court: Washington Supreme Court; January 22, 1976; Washington; State Supreme Court
Arthur Rockwell was convicted of second-degree burglary and grand larceny, leading to his appeal after the Court of Appeals reversed the conviction due to the trial court's refusal to give a proposed jury instruction on the multiple-hypothesis test for circumstantial evidence. The proposed instruction emphasized that suspicion alone is insufficient for conviction and that the jury must consider the evidence favorably toward the defendant where plausible. The Supreme Court of Washington reversed the Court of Appeals' decision, referencing its earlier ruling in State v. Gosby, which determined that the multiple-hypothesis circumstantial evidence instruction is no longer necessary. The Court clarified that juries should be instructed only to find the defendant guilty beyond a reasonable doubt, regardless of whether the evidence is direct or circumstantial. The trial judge's instructions on reasonable doubt were deemed sufficient, and thus, the refusal to give the multiple-hypothesis instruction was not erroneous. The Court reinstated the trial court's judgment and overturned the Court of Appeals' ruling.