On January 6, 2026, the Washington state Court of Appeals reversed the conviction of James Padrta, who had been convicted of voting in both Oregon and Washington in November 2022. Here is the decision in State of Washington v Padrta, 59737-3-II.
The defendant had moved from Oregon to Washington in July 2022. When he registered in Washington, he filled out the form to show he had been registered in Oregon at his old address. If election procedures had been followed, Washington election officials should have notified Oregon election officials that the Oregon registration should be cancelled. But, something went wrong and Oregon was not notified. Both states send every registered voter a postal ballot. The defendant voted on both of them.
His conviction was reversed because the wording of the Washington criminal statute refers to voting twice “in the same election.” But the Court said the law was ambiguous, because the Oregon election was for officials in Oregon, and the Washington election was for officials in Washington. Therefore, the Court felt the two elections were not “the same election.” They said that if it had been a presidential election, their conclusion would be different. The vote was 2-1. Washington state will probably appeal to the State Supreme Court.
The Court’s mention of presidential elections could be challenged. Each state elects its own presidential electors, and the electors, not the voters, then choose the president. It would be logical to argue that the “presidential election” in each state was not the same election, but rather two separate elections for different candidates for presidential elector.
The Court majority depended on a similar decision from Arizona. The state did not cite any precedents that supported its position.
It seems logically that it is Oregon that should have prosecuted the defendant, because he voted in a November election even though he had moved out of Oregon five months earlier.