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Washington v. Sayler – Case Brief Summary (Washington)

In Washington v. Sayler, 36 Wn. App. 230, 673 P.2d 870 (Wash. Ct. App. 1983), the court determined that the facts were insufficient to sustain a conviction for an exposure in a public place.

The case involved a defendant who masturbated in front of two boys while in his garage.

Noting that "public" does not mean "private," the court stated, id. at 873:

We believe it appropriate in interpreting a statute to use simple logic and to give ordinary English words their ordinary meaning.... Webster tells us that "public" means "1. a place accessible or visible to all ..." "open" means "2a: completely free from concealment: exposed ..." and "expose" means "2: to lay open to view ..." Webster's Third New International Dictionary (Merriam 1969)... thus, the forbidden conduct is public conduct, and public, in the context, must refer to place.