The State of Washington, Respondent v. John T. Ryan, Appellant

Summary

The court held that RCW 9A.44.120 is facially consistent with the federal and state confrontation clauses, but the trial court improperly admitted the children's hearsay statements because the State neither demonstrated their unavailability nor established sufficient indicia of reliability. Without those statements, the defendant's confession alone did not establish the corpus delicti. The court rejected the separation-of-powers, title, and ex post facto challenges and reversed and remanded the convictions. Justice Dolliver, concurring, would have relied solely on the absence of a demonstrated good-faith effort to produce the children, while Justice Dimmick, concurring, would have reversed solely for the trial court's legal error concerning competency and unavailability.