State v. Beadle

265 P.3d 863 (2011)

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State v. Beadle

Washington Supreme Court
265 P.3d 863 (2011)

RW

Facts

The State of Washington (plaintiff) prosecuted Steven Beadle (defendant) for an incident involving the attempted rape of three-year-old BA. Following the incident, BA had several encounters with adults to whom she gave consistent and credible verbal and demonstrative accounts of what happened. These encounters included a formal interview with a police detective who was gathering evidence against Beadle and informal exchanges between BA and her parents and mental-health counselors. Beadle was not present during any of these encounters. When Beadle came to trial, BA refused to testify and panicked each time anyone pressed her to do so. BA rebuffed every effort the trial judge made to accommodate her, including the judge’s offer to let BA testify by closed-circuit television instead of from the witness stand. In light of these rebuffs, the judge ruled that the girl was unavailable to testify. Instead, the judge admitted the hearsay testimony of the adults to whom BA had described the incident. This testimony was overwhelmingly corroborated by other evidence. The jury found Beadle guilty of child molestation, and an intermediate appellate court affirmed his conviction. Beadle appealed to the Washington Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Madsen, C.J.)

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