State of Washington v. Jason Michael Walker

CourtCourt of Appeals of Washington
DecidedFebruary 17, 2026
Docket40441-2
StatusUnpublished

This text of State of Washington v. Jason Michael Walker (State of Washington v. Jason Michael Walker) 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.

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State of Washington v. Jason Michael Walker, (Wash. Ct. App. 2026).

Opinion

FILED FEBRUARY 17, 2026 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) ) No. 40441-2-III Respondent, ) ) v. ) ) JASON MICHAEL WALKER, ) UNPUBLISHED OPINION ) Appellant. )

COONEY, J. — Jason Walker was convicted of escape in the second degree

following a jury trial. Mr. Walker appeals, arguing there was insufficient evidence to

support the conviction, among other claimed errors. We agree the evidence was

insufficient to support Mr. Walker’s conviction. We reverse the conviction and remand

for the trial court to dismiss the charge with prejudice. With this holding, we decline to

review Mr. Walker’s remaining assignments of error. No. 40441-2-III State v. Walker

BACKGROUND

On March 23, 2020, during the onset of the COVID-19 pandemic, Mr. Walker

escaped from the Yakima County Jail. Following a disturbance where jail officials

deployed pepper spray, Mr. Walker exited the jail through an annex door breached by

other inmates. Mr. Walker was promptly apprehended.

The State charged Mr. Walker with escape in the second degree under RCW

9A.76.120(1)(b), alleging that “after having been charged with Forgery and/or Unlawful

Possession of a Firearm and/or Possession of a Controlled Substance, felonies, [he]

knowingly escaped from custody.” Clerk’s Papers (CP) at 17. The matter proceeded to a

jury trial.

On the morning of trial, the court suggested, “The information lists the felonies

that Mr. Walker was charged with as unlawful possession of a firearm and possession of

a controlled substance. I propose to just generalize to ‘a felony.’” Rep. of Proc. (RP) at

96. In response, the prosecutor stated that he intended on moving to amend the

information to “just simply being in a detention facility” under RCW 9A.76.120(1)(a).

RP at 96-97. The prosecutor reasoned that doing so “simplifies the jury instructions”

and “eliminates the potential for any prejudice—[because the information] won’t discuss

2 No. 40441-2-III State v. Walker

the nature of the felony charges against [Mr. Walker].” RP at 97. The court granted

the State’s motion. 1

At trial, Yakima County Jail records custodian, Sandra Bess, testified about

exhibit 3, a “release report” pertaining to Mr. Walker that she had signed. RP at 295-96.

Exhibit 3 was admitted into evidence. Ms. Bess testified that Mr. Walker “was booked

into the jail on March 18th, 2020” and that the release report “shows his release date as

May 15th of 2020.” RP at 297-98. The release report, depicted below, provided minimal

information as to why Mr. Walker was detained.

Ex. 3.

Yakima County Jail Corrections Officer Josh Clark testified that when someone is

booked into the jail, “[w]e find out who they are [and] what the charging documents are

At the conclusion of the State’s case, the court again granted the State’s motion 1

to amend the information. The second amended information is inconsequential to our holding.

3 No. 40441-2-III State v. Walker

if we have reason to hold them.” RP at 302. Officer Clark testified that individuals are

detained in jail for “citation[s], criminal citations, felony warrants, [suspect information

reports], stuff like that” and can be from “other counties—confirmed on the warrant” or

from other states. RP at 303.

Mr. Walker did not contest that he was an inmate at the jail nor that he escaped

from the jail. Rather, Mr. Walker testified that he fled the jail “[t]o get away from the

disturbance, to get away from not being able to breathe, to get away from the officers

that—at that moment in time I feared for my life,—thought they were going to do

something, they were doing something.” RP at 419.

The jury was instructed on the law at the conclusion of the evidentiary portion of

the trial. Relevant to this appeal, the jury was instructed that to convict Mr. Walker of

escape in the second degree, the jury must find beyond a reasonable doubt:

(1) That on or about March 23, 2020, [Mr. Walker] escaped from a detention facility;

(2) That [Mr. Walker] knew that his actions would result in leaving confinement without authorization; and

(3) That this act occurred in the State of Washington.

CP at 237. The court defined “detention facility” as “any place used for the confinement

of a person arrested for, charged with, or convicted of an offense.” CP at 238.

Following deliberations, the jury found Mr. Walker guilty of escape in the second

degree. The court later sentenced Mr. Walker to 55 months of confinement.

4 No. 40441-2-III State v. Walker

Mr. Walker timely appeals.

ANALYSIS

Mr. Walker argues the evidence admitted at trial was insufficient to support a

conviction for escape in the second degree. We agree.

Due process imposes the burden of proving every element of a crime charged

beyond a reasonable doubt on the State. State v. Smith, 155 Wn.2d 496, 502, 120 P.3d

559 (2005). Sufficiency of the evidence is a question of law this court reviews de novo.

State v. Rich, 184 Wn.2d 897, 903, 365 P.3d 746 (2016). In a sufficiency of the evidence

analysis, the court considers 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. Salinas, 119 Wn.2d 192, 201, 829 P.2d 1068 (1992). A

challenge to the sufficiency of the evidence “admits the truth of the State’s evidence and

all inferences that reasonably can be drawn therefrom.” Id. The remedy for insufficient

evidence is dismissal with prejudice. State v. Irby, 187 Wn. App. 183, 204, 347 P.3d

1103 (2015).

Circumstantial and direct evidence are equally reliable, and we do not review

credibility determinations. State v. Zghair, 4 Wn.3d 610, 620, 567 P.3d 1 (2025).

However, “inferences based on circumstantial evidence must be reasonable and cannot

be based on speculation.” State v Vasquez, 178 Wn.2d 1, 16, 309 P.3d 318 (2013).

5 No. 40441-2-III State v. Walker

Mr. Walker argues there was insufficient evidence presented at trial to sustain the

conviction because the State failed to prove that he escaped from a detention facility.

Specifically, Mr. Walker contends the State was required to prove that the Yakima

County Jail confined people “arrested for, charged with, or convicted of an offense” and

that he was confined for one of those reasons. Appellant’s Opening Br. at 18. The State

responds that, in viewing the evidence in a light most favorable to it, circumstantial

evidence allowed the jury to reasonably infer that Mr. Walker was detained for one of the

enumerated reasons.

An element of escape in the second degree is that the accused “knowingly escapes

from a detention facility.” RCW 9A.76.120(a). A “detention facility” is “any place used

for the confinement of a person . . . arrested for, charged with or convicted of an offense,”

among other definitions.

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Related

State v. Salinas
829 P.2d 1068 (Washington Supreme Court, 1992)
State v. Monday
257 P.3d 551 (Washington Supreme Court, 2011)
State v. Gomez
217 P.3d 391 (Court of Appeals of Washington, 2009)
State v. Hendrix
35 P.3d 1189 (Court of Appeals of Washington, 2001)
State v. Smith
120 P.3d 559 (Washington Supreme Court, 2005)
State v. Smith
155 Wash. 2d 496 (Washington Supreme Court, 2005)
State v. Monday
171 Wash. 2d 667 (Washington Supreme Court, 2011)
State v. Vasquez
309 P.3d 318 (Washington Supreme Court, 2013)
State v. Rich
365 P.3d 746 (Washington Supreme Court, 2016)
State v. Hendrix
109 Wash. App. 508 (Court of Appeals of Washington, 2001)
State v. Gomez
152 Wash. App. 751 (Court of Appeals of Washington, 2009)
State v. Irby
347 P.3d 1103 (Court of Appeals of Washington, 2015)

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