State v. Woolfolk
In State v. Woolfolk, 95 Wn. App. 541, 547-48, 977 P.2d 1 (1999), the defendant was convicted of possession of a controlled substance with intent to manufacture or deliver while armed with a firearm. Woolfolk, 95 Wn. App. at 543.
Defense counsel wished to argue to the jury that Woolfolk had no knowledge of the gun, but was denied the opportunity to do so.
The Court of Appeals reversed Woolfolk's conviction, stating the following:
There is evidence in the record from which an inference may be drawn that Woolfolk did not know about the gun. . . . Woolfolk was not prevented from reminding the jury of this evidence but was precluded from driving home the crucial point that if they believed Woolfolk when he said he did not know about the gun, then they should find that he was not armed. Woolfolk should not be precluded from arguing his theory of the case to the jury, and we find that the trial court erred in granting the State's motion in limine. Woolfolk, 95 Wn. App. at 550.