The State of Washington v. Andrea Marie Rich

Summary

The Washington Supreme Court held that proof of DUI alone, or speeding alone, does not establish reckless endangerment, because each offense lacks the recklessness mens rea of knowing disregard of a substantial risk combined with gross deviation from reasonable conduct. Applying that rule, the court held the combined evidence here—speeding past a marked patrol car in traffic, a blood alcohol level more than twice the legal limit, Rich's awareness that she was 'tipsy,' and a young child in the front passenger seat—sufficient for a rational juror to find beyond a reasonable doubt that Rich recklessly created a substantial risk of death or serious physical injury to her nephew. The court reversed the Court of Appeals and reinstated the reckless endangerment conviction. No separate opinions were filed.