Seattle Attorneys Blog
A new decision from the Washington Supreme Court has changed how the charge of interfering with reporting domestic violence under RCW 9A.36.150 is analyzed in court. In State v. Buck, decided May 14, 2026, the Court held that this offense is a single crime — not three separate “alternative means” of committing a crime. If you are facing a domestic violence-related charge in King, Pierce, or Snohomish County, the criminal defense attorneys at Blair & Kim can explain how this ruling may affect the arguments available in your case.
The distinction sounds technical, but it touches a constitutional right that matters in every criminal trial: the right to a unanimous jury.
The Charge: Interfering With Reporting Domestic Violence
Under RCW 9A.36.150, a person commits this crime when they (1) commit an underlying domestic violence offense and (2) prevent or try to prevent the victim or a witness from calling 911, getting medical help, or making a report to law enforcement.
In Buck, the defendant was accused of physically restraining the other parent of his children during an argument, then taking her phone when she said she was going to call the sheriff. He was convicted of interfering with reporting domestic violence and challenged the conviction on appeal.
What Is an “Alternative Means” Crime?
This is where the case gets interesting for defense strategy. In Washington, criminal defendants have a constitutional right to a unanimous jury verdict under article I, section 21 of the state constitution. An “alternative means” crime is an offense that can be committed in more than one distinct way. When a statute creates alternative means, the State must present sufficient evidence to support each means the jury is allowed to consider — otherwise the conviction cannot stand.
That rule can be a powerful defense tool. If a charge is an alternative means crime and the prosecution leaves one of the means unsupported by evidence, the defense may have grounds to challenge the verdict. For years, defendants charged under the DV reporting statute relied on a 2008 Division One decision, State v. Nonog, which had treated the statute as an alternative means crime.
What the Court Decided in Buck
The Court held that interfering with reporting domestic violence is a single crime, not three. It reached that result by focusing on the defendant’s criminal conduct — not the conduct of the victim or witness — in resolving a split between two divisions of the Court of Appeals.
The three listed actions in the statute — calling 911, getting medical assistance, reporting to police — all describe things the victim or witness does, not different ways the defendant commits a crime. As the Court put it, the critical conduct is the interference itself. Because the only criminalized conduct is the interference, the statute defines one crime, not three. The Court affirmed Division Three and overruled Nonog.
| Under Buck, the State generally does not need to prove each listed reporting method (calling 911, obtaining medical help, reporting to police) separately, because RCW 9A.36.150 now defines a single crime. The State must still prove the interference and the underlying domestic violence offense. |
If you have questions about how this decision applies to a pending charge, Blair & Kim’s criminal defense team is available to review the facts of your situation. Call (206) 622-6562 to talk through your options.
Why This Matters for People Facing DV Charges
On its face, Buck narrows one avenue of defense — defendants can no longer argue that the State failed to prove each separate reporting method. But the decision does not weaken the State’s core burden. The prosecution must still prove, beyond a reasonable doubt, that an underlying domestic violence offense occurred and that the defendant prevented or attempted to prevent a report.
Several defense issues remain very much alive after Buck:
- Whether an underlying DV crime actually occurred. The interference charge is built on top of a predicate domestic violence offense. If the State cannot prove that, the interference charge fails too.
- Whether the alleged interference happened at all. The statute requires preventing or attempting to prevent a report. The facts often matter enormously here.
- Constitutional and evidentiary challenges unrelated to the alternative means doctrine, including challenges to how evidence was obtained.
Domestic violence allegations also frequently overlap with family law matters — protection orders, parenting plans, and divorce proceedings can all be affected by a criminal charge. Because Blair & Kim handles both criminal defense and family law, the firm can help clients understand how a criminal case and a family law case may influence one another.
Common Questions
Is interfering with reporting domestic violence one crime or three in Washington?
After State v. Buck (2026), it is a single crime under RCW 9A.36.150, not three alternative means. The State no longer has to support each listed reporting method (calling 911, obtaining medical help, reporting to police) with separate evidence.
What is an alternative means crime?
An alternative means crime is an offense that can be committed in more than one distinct way. When a statute creates alternative means, the State must present sufficient evidence to support each means presented to the jury, because Washington defendants have a constitutional right to a unanimous jury verdict.
Does the Buck decision make it easier to convict someone of a DV charge?
It removes one specific defense argument, but the State must still prove beyond a reasonable doubt that an underlying domestic violence offense occurred and that the defendant prevented or attempted to prevent a report. Other defenses remain available.
Domestic Violence Charges Across the Seattle Metro
Blair & Kim’s criminal defense team represents people facing domestic violence and related charges throughout King County, Pierce County, and Snohomish County, including in Bellevue, Kirkland, and Redmond. With former prosecutor experience across three Washington counties and a familiarity with local courts, the firm draws on experience with how these cases are charged and tried locally.
Talk to a Seattle Criminal Defense Attorney
A domestic violence charge can carry serious consequences for your freedom, your record, and your family. If you or someone you know is facing a charge under RCW 9A.36.150 or any related offense, the attorneys at Blair & Kim are ready to help. Call (206) 622-6562 or contact Blair & Kim to discuss your case.