Sullivan v. State

In Sullivan v. State, 766 P.2d 51, 56 (Alaska Ct. App. 1988), the Alaska Court of Appeals held that evidence that the defendant wrote notes to a minor asking her to "be my girlfriend," "kiss me," let him "feel" and "kiss" her "private parts," and "take off her clothes" "established only that he engaged in preparatory conduct and not that he took a substantial step toward sexual conduct" with the minor as required for attempted sexual abuse of a minor.