Court of Appeals of Washington Rejects Appeal, Finding the Phrase “Having a ‘Beef’ With Someone” Doesn’t Have a Racial Connotation

Does the phrase “having a ‘beef’ with someone” have a racial connotation? That was the question addressed by the Court of Appeals of Washington in its recent opinion in State v. Bellerouche, 2025 WL 830775 (Wash. App. 2025).

In Bellerouche, “[a] jury convicted Bernard Bellerouche of assault in the first degree and unlawful possession of a firearm, for shooting Terrence Robinson three times, including once in the face.” On appeal, “Bellerouche, who is African American, argue[d] the State committed race-based prosecutorial misconduct by using the term ‘beef’ five times during trial, largely when discussing whether he and Robinson, who is also Black, had a dispute prior to the shooting.”

The court resolved the issue as follows:

Bellerouche argues that “beef” “is frequently used by Black hip-hop and rap artists, and connotes violence, gun violence in particular.” Bellerouche cites to two sources in support of his understanding of the meaning of this term: (a) non-standard dictionaries and (b) scholarly sources, news articles, and rap lyrics, which he claims define the term’s meaning in popular culture….

Bellerouche relies on the online Urban Dictionary, Wiktionary, and the etymology within the Oxford English Dictionary in asking us to understand the term “beef” as an “argument between two young Black men.”

Although in a slightly different context, we have long urged courts to avail themselves of and to utilize, not just any resource, but a “standard dictionary” when seeking to understand an undefined term….Bellerouche’s citations are not to the standard dictionaries we have relied on in the past to define a term….Using a standard dictionary, the meaning of the term “beef” is simply slang for a “grievance or ground for complaint” without any racialized sense of the word. Webster’s Third International Dictionary 196 (2002). The State cites to Webster’s and it is hardly “cherry picking” dictionaries, as Bellerouche asserts to rely on that dictionary rather than the many found in the recesses of the Internet to understand the meaning or content of the term.

At oral argument, Bellerouche’s counsel “absolutely acknowledge[d] that ‘beef’ has gained much wider usage,” but averred that “we still have to be careful with colloquialisms.”…It is true that prosecutors should be careful with colloquialisms, but we should assess the words prosecutors use—in the first instance and when necessary—by reference to the general meaning of the term found in a standard dictionary, particularly when a term is widely used.

As to his citations in support of the pop culture definition, Bellerouche avers that “the late rapper Notorious B.I.G., who was himself a victim of gun violence,” wrote a song containing numerous references to the term “beef.” Bellerouche also cites to “Lil Wayne,” who also wrote a rap song that references “beef.” And Bellerouche cites to a law review article and a newspaper analyzing such references.

Our Supreme Court in Bagby, however, appeared to caution against determining a word’s meaning through pop culture references….There, five justices disagreed with the main opinion’s argument that the State “prim[ed] the jury to think of Michael Vick and associate Bagby with animal abuse.”…We likewise should be wary then about effectively searching the Internet for a term and deriving meaning from the various hits that appear. A standard dictionary is a better to place to start….

At a minimum, this exercise shows that, unlike the terms or phrases utilized in cases like Monday,…a racial meaning is not unmistakably or exclusively tied to the term “beef.” In other words, we hold that the term “beef” does not have a clear racial connotation to an objective observer, absent additional context.

-CM