State v. Hickman

Summary

The court held that an unobjected-to jury instruction adding venue as an element becomes the law of the case, requiring the State to prove venue beyond a reasonable doubt. Because the State failed to present sufficient evidence that Hickman presented or caused a fraudulent insurance claim in Snohomish County, the court reversed the conviction and dismissed the charges with prejudice. The opinion also held that retrial is barred after reversal for insufficient evidence.