K.R.L., an eight-year-old boy, was convicted of residential burglary by the Superior Court, Clallam County, and he appealed. The Court of Appeals reversed.

Facts

In July 1990, K.R.L., who was then 8 years and 2 months old, was playing with a friend behind a business building in Sequim. Catherine Alder, who lived near the business, heard the boys playing and she instructed them to leave because she believed the area was dangerous. Alder said that K.R.L.’s response was belligerent, the child indicating that he would leave “in a minute.” Losing patience with the boys, Alder said “no, not in a minute, now, get out of there now.” The boys then ran off. Three days later, during daylight hours, K.R.L. entered Alder’s home without her permission. He proceeded to pull a live goldfish from her fishbowl, chopped it into several pieces with a steak knife, and “smeared it all over the counter.” He then went into Alder’s bathroom and clamped a “plugged in” hair curling iron onto a towel....

1. Was the trial judge or the Supreme Court of Washington right in the ruling on the capacity of K.R.L. to form criminal intent? Back up your answer with facts from the case.

2. Did K.R.L. know what he was doing intellectually yet not sufficiently appreciate what he was doing? What facts support this conclusion?

3. Should it matter whether he appreciated what he did as long as he knew what he did was wrong? Explain your answer.