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SEATTLE v. HEIN

The Supreme Court of Washington. Department One.
Nov 8, 1990
Important Paras
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[1] Indictment and Information — Sufficiency — Omission of Element — In Citation. The essential elements rule, under which a charging document is subject to dismissal for failure to allege facts supporting every statutory element of the charged crime, applies to citations.

PER CURIAM.

[1] The City of Seattle's motion to modify the ruling of the Commissioner of this court in the above entitled case is denied. The essential elements rule, discussed in State v. Leach, 113 Wn.2d 679, 782 P.2d 552 (1989), applies to citations.