The court of appeals reversed a judgment of conviction. The court held that the district court committed prejudicial error in failing to read several highly inflammatory literary articles before admitting them at trial as evidence of an alleged arsonist’s propensity to commit her alleged crimes. The district court also erred in closing a pretrial hearing to the public and in failing adequately to address potentially prejudicial news stories that were reported in the local media during deliberations.

When a fire was set in the office of a professor at the University of Washington, the activist environmental group Earth Liberation Front (ELF) claimed responsibility. The fire, which spread to the rest of the building, caused more than $6 million in damage.