State v. Workman, 584 P.2d 382 (Wash. en banc 1978)

Facts: ∆ and Hughes drove to Idaho, then back, planning to rob a gas station. They cased it with a .22 rifle and gunny-sack masks. An employee saw them and called police. As ∆s walked away (claiming they had decided to abandon), police arrested them; the rifle was hidden under their clothing. Charged with attempted first-degree robbery.
Issue: Whether ∆s' acts constituted a "substantial step," and whether abandonment of a completed attempt is a defense.
Rule: A substantial step toward the target crime, undertaken with intent, completes attempt. Under the CL majority, once attempt is complete, it cannot be abandoned. Under the MPC / CL minority, abandonment is a defense only if complete and voluntary—not driven by extrinsic circumstances (e.g., seeing police).
Analysis: ∆s armed themselves, drove to the scene, and concealed the weapon—plainly a substantial step. Their walking away in response to outside circumstances (employee's notice) was not voluntary. The jury, properly instructed, returned a guilty verdict.
Judgment: Conviction affirmed.

Reading: pp. 278–80. See Abandonment and Ch. 6—Attempt.