The Washington Supreme Court issued a significant ruling on May 14, 2026, regarding the legal interpretation of a law related to domestic violence. The case, State v. Buck (No. 104170-5), involved Leif Buck, who was convicted of interfering with the reporting of domestic violence. The court's decision clarifies how this law should be understood and applied, particularly concerning jury verdict requirements.

This ruling is important because it affects how similar cases will be handled in the future, especially regarding the rights of defendants and the requirements for jury unanimity. The outcome may influence how domestic violence cases are prosecuted and how defendants can defend themselves against such charges.

Background

Leif Buck and A.H. share two children but live separately. In the summer of 2021, A.H. visited Buck's home to discuss a parenting plan. During this visit, Buck became violent, lunging at A.H., holding her down, and dragging her across the floor. When A.H. attempted to call the sheriff, Buck took her cell phone to prevent her from making the call. A.H. later reported the incident to the sheriff's office and sought medical attention for her injuries.

The State charged Buck with several offenses, including interfering with the reporting of domestic violence, under Washington law (RCW 9A.36.150). At trial, the jury found Buck guilty. However, during the appeal, Buck argued that his conviction violated his right to a unanimous jury verdict. He claimed that the law should be interpreted as an alternative means crime, which would require the jury to agree on how he committed the offense.

The Court of Appeals initially ruled that interference with reporting domestic violence was not an alternative means crime, which conflicted with a previous ruling from Division One of the Court of Appeals. This conflict prompted the Washington Supreme Court to review the case to resolve the differing interpretations.

The Ruling

The Washington Supreme Court ruled that interference with reporting domestic violence is not an alternative means crime. The court affirmed the decision made by Division Three of the Court of Appeals. Justice Barbara Madsen, serving as a justice pro tempore, stated, "We hold that interference is not an alternative means crime and affirm Division Three." This ruling clarifies that the law defines a single crime of interference rather than multiple ways to commit it.

The court's analysis focused on the statutory language of RCW 9A.36.150, which outlines the offense. The court emphasized that the prohibited conduct is the defendant's interference with the victim's ability to report domestic violence, rather than different methods of reporting. The court concluded that the law does not describe distinct acts but rather focuses on one type of criminal conduct.

Impact

This ruling has significant implications for future cases involving domestic violence. By clarifying that interference with reporting domestic violence is a single crime, the court's decision reinforces the requirement for a unanimous jury verdict based on the defendant's conduct. This means that juries will need to agree on the specific actions of the defendant that constitute the crime, rather than considering various alternative methods of committing the offense.

The decision may also influence how prosecutors approach domestic violence cases. With a clearer understanding of the law, prosecutors may adjust their strategies in charging and presenting evidence in similar cases. This ruling could lead to more consistent outcomes in domestic violence prosecutions across Washington State.

What's Next

Details were not available in the court filing regarding whether this ruling could be appealed or if there are related cases pending. However, the Washington Supreme Court's decision in State v. Buck sets a clear precedent for how the law will be interpreted moving forward.