State v. Snapp
2004 Wash. App. LEXIS 9, 119 Wash. App. 614, 82 P.3d 252 (2004)
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Rule of Law:
The validity of a court-issued no-contact order is not an implied essential element of the offense of violating such an order. The State is not required to prove the order's validity beyond a reasonable doubt unless the defendant first raises a timely and specific substantive challenge to it.
Facts:
- On September 14, 2000, Danny L. Snapp was charged with four crimes of domestic violence against his wife, Tonya.
- An initial no-contact order was issued but later terminated on September 28, 2000, at Tonya's request.
- On November 6, 2000, police responded to another domestic dispute at the Snapp residence.
- As officers arrived, Snapp saw them and sped away from the residence in his vehicle.
- Officers captured Snapp, found him to be intoxicated, and cited him for driving under the influence (DUI).
- Because the DUI arrest occurred during a domestic violence investigation and while the prior domestic violence charges were still pending, the court reissued a pretrial no-contact order on November 7, 2000.
- On February 6, 2001, Snapp allegedly kicked and hit Tonya in violation of the reissued no-contact order.
Procedural Posture:
- The State charged Danny L. Snapp in the trial court with felony violation of a no-contact order and interfering with reporting domestic violence.
- The charge of interfering with reporting domestic violence was dismissed.
- A jury convicted Snapp of felony violation of a no-contact order.
- The trial court sentenced Snapp to six months in jail, and later amended the sentence to include a batterer's treatment program and continued no-contact provisions.
- Snapp appealed his conviction and the amended sentence to the Washington Court of Appeals.
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Issue:
Is the validity of a no-contact order an implied essential element of the crime of violating such an order that the State must prove beyond a reasonable doubt in the absence of a specific challenge by the defendant?
Opinions:
Majority - Quinn-Brintnall, A.C.J.
No. The validity of a no-contact order is not an implied element of the crime that the State must prove in every prosecution. A court order is presumed valid, and the State is not required to anticipate and disprove every potential defect. The burden is on the defendant to raise a specific, substantive challenge to the order's validity. Only after such a challenge is raised must the State prove the validity of the order in that specific regard beyond a reasonable doubt. The court also held that it had the authority to reissue the no-contact order in the pending domestic violence case following Snapp's DUI arrest, as court rules permit amending release conditions based on new information or a change in circumstances.
Analysis:
This decision clarifies the evidentiary burdens in prosecutions for violations of court orders, specifically no-contact orders. It establishes that court orders carry a presumption of validity, relieving the State from the cumbersome task of proving the absence of any possible procedural or substantive defect in the underlying order as part of its case-in-chief. By placing the initial burden on the defendant to articulate a specific flaw, the ruling streamlines prosecutions and prevents defendants from making vague, collateral attacks on prior judicial determinations. This reinforces the finality and enforceability of court orders while preserving a defendant's right to challenge genuinely invalid orders.
