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MATTER OF RICHMOND

No. 37057-7-III.

482 P.3d 971 (2021)

In the MATTER OF the Personal Restraint of: Joseph Andrew RICHMOND, Petitioner.

Court of Appeals of Washington, Division 3.

Filed March 18, 2021.

Attorney(s) appearing for the Case

Jeffrey Erwin Ellis , Law Office of Alsept & Ellis, 621 SW Morrison St. Ste. 1025, Portland, OR, 97205-3813, for Petitioner.

Gregory Lee Zempel , Kittitas County Prosecuting Attorney, 205 W 5th Ave. Ste. 213, Ellensburg, WA, 98926-2887, for Respondent.

OPINION PUBLISHED IN PART

¶ 1 The use of animal analogies at trial is problematic. Many animal comparisons operate as racist code. Others are simply dehumanizing. But there is no hard and fast rule. Not all animal analogies are inherently improper. When a particular analogy does not clearly convey an improper message...

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