State of Washington v. James Anthony Padrta

CourtCourt of Appeals of Washington
DecidedJanuary 6, 2026
Docket59737-3
StatusPublished

This text of State of Washington v. James Anthony Padrta (State of Washington v. James Anthony Padrta) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Washington v. James Anthony Padrta, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

January 6, 2026

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II

STATE OF WASHINGTON, No. 59737-3-II

Respondent,

v.

JAMES ANTHONY PADRTA, PUBLISHED OPINION

Appellant.

MAXA, J. – James Padrta appeals his conviction and sentence for voting both in

Washington and in Oregon in November 2022 in violation of RCW 29A.84.650(1).

RCW 29A.84.650(1) states, “Any person . . . who intentionally votes or attempts to vote

in both this state and another state at any election, is guilty of a class C felony.” It is undisputed

that Padrta voted both in Washington and in Oregon in November 2022. Because 2022 was a

midterm election year, there was no overlap in the candidates or issues on the Washington and

Oregon ballots.

Padrta argues that the State presented insufficient evidence to convict him of voting in

two states in the same election under RCW 29A.84.650(1) because “election” must be

interpreted as referring to a choice between specific candidates or propositions, and the

candidates on Washington and Oregon ballots were different. The State argues that the only No. 59737-3-II

reasonable interpretation of “election” is that it is the process of voting for candidates, because

Padrta’s interpretation would make it impossible to violate the relevant portion of RCW

29A.84.650(1).

This is the first case involving the interpretation of RCW 29A.84.650(1). We conclude

that the plain language of the statute is subject to two reasonable interpretations, making the

statute ambiguous.

In light of an Arizona case that supports Padrta’s position and the presumed intent of the

legislature to prohibit someone from voting twice for the same candidate or issue, we resolve the

ambiguity by adopting Padrta’s interpretation. Under this interpretation, the Washington election

and the Oregon election were not the same election. Therefore, we hold that the evidence was

insufficient to convict Padrta of repeat voting under RCW 29A.84.650(1).

Accordingly, we reverse Padrta’s conviction and remand to the trial court with

instructions to dismiss the case with prejudice.1

FACTS

Padrta previously lived in Oregon and was registered to vote there. In July 2022, Padrta

moved to Washington. Padrta obtained a Washington driver’s license, which caused him to

become a registered voter in Washington. Apparently, Padrta’s registration in Oregon was not

canceled.2 Therefore, Padrta was registered to vote in both states.

1 Padrta also argues that the trial court abused its discretion when it admitted his Oregon voting records into evidence. Because we reverse Padrta’s conviction, we do not address this argument. 2 RCW 29A.08.135(1) states, “When a person who has previously registered to vote in another state applies for voter registration in Washington, the person shall provide on the registration form all information needed to cancel any previous registration. Notification must be made to the state elections office of the applicant’s previous state of registration.” Apparently, Oregon was not notified when Padrta became registered to vote in Washington.

2 No. 59737-3-II

Padrta voted on the Lewis County, Washington ballot for the November 2022 general

election and mailed it on October 25, 2022. The ballot was received by the Lewis County

Auditor two days later. Padrta received a Clackamas County, Oregon ballot for the November

2022 general election in his post office box in Oregon. He voted on that ballot and mailed it on

November 5, 2022. Oregon election officials received Padrta’s ballot on November 8, 2022.

The Lewis County Auditor’s Office was informed that Padrta returned ballots in both

states through a vote monitoring system. The State charged Padrta with repeat voting in

violation of RCW 29A.84.650(1).

The case proceeded to a bench trial. Jolene Manuel, the Lewis County election manager,

testified that Lewis County received a ballot from Padrta for Washington’s November 2022

general election. She also testified that she received information from the Washington Secretary

of State that Padrta had voted in both Washington and Oregon.

Manuel stated that there is a system called the Electronic Registration Information Center

(ERIC), which state election officials use to monitor voting in various states. The ERIC system

identified that Padrta had voted in both Oregon and Washington, which caused Oregon officials

to send Padrta’s voting records to the Washington Secretary of State. The Secretary of State

forwarded those records to Lewis County. The trial court admitted certified copies of the Oregon

voting records, which Manuel had reviewed. These records showed that Padrta voted in

Clackamas County, Oregon in November 2022.

Matthew Wallace, a detective sergeant for the Lewis County Sheriff’s Office, testified

that he spoke with Padrta after receiving information from Manuel. Padrta acknowledged to

Wallace that he had voted on ballots in both Washington and Oregon.

3 No. 59737-3-II

Padrta testified that he voted in both the Washington and Oregon elections. He also

acknowledged that he already had voted in Washington when he picked up his Oregon ballot.

Padrta stated that he did not vote for identical candidates or issues in Washington and Oregon.

He stated, “It was totally different issues, totally different representatives.” Rep. of Proc. ((May

14, 2024) at 42.

The trial court convicted Padrta of repeat voting. The court entered the following

conclusions of law:

2.3 The defendant intentionally voted in Washington and in Oregon. 2.4 This voting occurred in the same election.

Clerk’s Papers at 10-11. The court did not impose any time in confinement.

Padrta appeals his conviction.

ANALYSIS

A. SUFFICIENCY OF THE EVIDENCE – REPEAT VOTING

Padrta argues that the State presented insufficient evidence to convict him of repeat

voting in violation of RCW 29A.84.650(1) because he did not vote in both Washington and

Oregon in the same “election.” We agree.

1. Legal Principles

The test for determining sufficiency of the evidence in a bench trial is whether, after

viewing the evidence in the light most favorable to the State, any rational trier of fact could have

found guilt beyond a reasonable doubt. State v. Roberts, 5 Wn.3d 222, 231, 572 P.3d 1191

(2025).

Padrta’s argument depends on the statutory interpretation of RCW 29A.84.650(1).

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Related

State v. Hannah
355 P.3d 607 (Court of Appeals of Arizona, 2015)
State v. Schwartz
450 P.3d 141 (Washington Supreme Court, 2019)

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State of Washington v. James Anthony Padrta, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-james-anthony-padrta-washctapp-2026.