State Of Washington, V. Jason Dominguez

CourtCourt of Appeals of Washington
DecidedJanuary 6, 2025
Docket83516-5
StatusUnpublished

This text of State Of Washington, V. Jason Dominguez (State Of Washington, V. Jason Dominguez) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Of Washington, V. Jason Dominguez, (Wash. Ct. App. 2025).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

JASON DOMINGUEZ, No. 83516-5-I Appellant,

v. DIVISION ONE

STATE OF WASHINGTON, UNPUBLISHED OPINION Respondent.

CHUNG, J. — Jason Dominguez was convicted of one count of rape of a

child in the second degree, one count of rape of a child in the third degree, and

one count of communicating with a minor for immoral purposes, all involving

H.S., the minor friend of his daughter. He seeks reversal of all three convictions

on several bases. He claims missing juror questionnaires deprive him of an

appellate record of sufficient completeness and, thus, violate his constitutional

right to appeal. He further claims the trial court erred by admitting evidence to

show his “lustful disposition” for the victim, allowing the State to amend the

information, and including H.S.’s initials in the to-convict instructions. He also

challenges statements by the prosecutor as misconduct and a variety of

community custody conditions imposed on him. We affirm his convictions.

However, we remand to the trial court to replace overbroad language on

conditions 21 and 24 and to strike the victim penalty assessment (VPA) and DNA

collection fee. No. 83516-5-I/2

FACTS

Dominguez and H.S. first met while living in Gold Bar, Washington, when

H.S. was 11 years old. She was initially introduced to Dominguez and his family

because she was in the same Girl Scout troop as Dominguez’s daughter.

In 2016 and 2017, when H.S. was aged 11 to 13, H.S. spent increasingly

more time with the Dominguez family. During this period, H.S. would spend the

night at the Dominguez house three times a month. The family took H.S. to the

zoo, the aquarium, and “just different things that [her family] didn’t have the

money to do.” H.S. considered Dominguez to be a “second father.”

In mid-2017, H.S.’s mother moved approximately five hours away to

Oroville, Washington, but permitted H.S. to stay in Gold Bar with her mother’s

friend. H.S. then moved to Oroville to join her family, but returned to Gold Bar for

visits, which included staying with the Dominguez family.

H.S. first received a cell phone when she was 12, and Dominguez began

contacting her shortly thereafter. From 2016 to 2019, the two would talk on the

phone and would use Facebook Messenger and Snapchat to communicate. They

also used Facebook Messenger to video chat.

In 2019, H.S. accused Dominguez of several incidences of rape, allegedly

beginning when she was 13 or 14 years old. In October 2021, a jury convicted

Dominguez as charged with rape of a child in the second degree, rape of a child

in the third degree, and communication with a minor for immoral purposes. The

court sentenced him to a life sentence, with the possibility of release after 170

2 No. 83516-5-I/3

months. The sentencing court also imposed numerous community custody

conditions, the VPA, and a DNA collection fee. Dominguez filed a timely appeal.

In October 2022, Dominguez filed a motion in this court to reverse his

convictions and remand for a new trial due to an inadequate record on appeal,

specifically, juror questionnaires. His counsel provided a declaration stating the

steps she had taken to locate the questionnaires, attesting that Dominguez’s trial

counsel, the trial prosecutor, Snohomish County clerk, and the trial judge’s law

clerk all indicated they did not have copies of the completed juror questionnaires.

A commissioner of this court denied the motion without prejudice, allowing

Dominguez to include argument regarding the adequacy of the record in his

merits brief. A panel of this court denied Dominguez’s motion to modify.

DISCUSSION

Dominguez challenges his convictions as well as his judgment and

sentence on multiple grounds. First, he asserts that because the completed juror

questionnaires are missing, he is deprived of a complete record sufficient for

review, and thus reversal of all his convictions is required. Second, he argues the

court impermissibly allowed evidence into trial solely for the purpose of showing

his “lustful disposition,” which is no longer a permissible basis for admitting

propensity evidence after the Washington Supreme Court’s decision in State v.

Crossguns, 199 Wn.2d 282, 505 P.3d 529 (2022). Third, he contends the court

erred by allowing the State to amend the information after completing its case-in-

chief. He additionally argues the use of the victim’s initials, rather than her full

name, on the jury instructions constituted an improper comment on the evidence.

3 No. 83516-5-I/4

Finally, he argues the State engaged in prosecutorial misconduct during its

closing arguments and challenges various community custody conditions.

I. Juror Questionnaires

Dominguez argues that because the completed juror questionnaires are

missing, the appellate record lacks sufficient completeness. He asserts that as a

result, his appellate counsel is unable to determine whether the jury was fair and

impartial, he cannot identify and fully litigate issues on appeal, and reversal for a

new trial is required. In particular, Dominguez claims jury selection was important

given his position in the community and the media attention his case received.

Article I, section 22 of the Washington Constitution guarantees the right to

appeal a criminal conviction. State v. Waits, 200 Wn.2d 507, 513, 520 P.3d 49

(2022). To pursue an effective appeal, a criminal defendant is “constitutionally

entitled to a ‘record of sufficient completeness.’ ” State v. Tilton, 149 Wn.2d 775,

781, 72 P.3d 735 (2003) (quoting State v. Thomas, 70 Wn. App. 296, 298, 852

P.2d 1130 (1993)). However, “[a] ‘record of sufficient completeness’ does not

translate automatically into a complete verbatim transcript.” Id. at 781 (quoting

Mayer v. City of Chicago, 404 U.S. 189, 194, 92 S. Ct. 410, 30 L. Ed. 2d 372

(1971)). Indeed, “alternative methods are acceptable, provided they permit

effective appellate review.” Waits, 200 Wn.2d at 513. “Effective review allows

counsel to determine which issues to raise on appeal and provides the relevant,

equivalent report of the trial record where the alleged issues occurred.” Id.

“Effective review on appeal also allows for other methods of reporting trial

proceedings in instances when a trial court record is deficient or missing.” Id. at

4 No. 83516-5-I/5

513-14. Other methods include “ ‘[a] statement of facts agreed to by both sides, a

full narrative statement based perhaps on the trial judge’s minutes taken during

trial or on the court reporter’s untranscribed notes, or a bystander’s bill of

exceptions might all be adequate substitutes, equally as good as a transcript.’ ”

Id. at 514 (quoting State v. Jackson, 87 Wn.2d 562, 565, 554 P.2d 1347 (1976)).

RAP 9.3 1 and RAP 9.4 2 set out possible alternative methods to prepare records

of trial proceedings.

Although the “RAPs anticipate that parties will work together to recreate a

lost or missing record,” the “State bears the burden of reconstructing the record

in a criminal appeal.” Waits, 200 Wn.2d at 519-20 n.7. Additionally, “[t]he burden

of showing that alternatives will suffice for an effective appeal rests with the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Mayer v. City of Chicago
404 U.S. 189 (Supreme Court, 1971)
Wooley v. Maynard
430 U.S. 705 (Supreme Court, 1977)
Bell v. Wolfish
441 U.S. 520 (Supreme Court, 1979)
Johnson v. United States
520 U.S. 461 (Supreme Court, 1997)
United States v. Matthew Henry Weber
451 F.3d 552 (Ninth Circuit, 2006)
State v. Lotze
593 P.2d 811 (Washington Supreme Court, 1979)
State v. Brett
892 P.2d 29 (Washington Supreme Court, 1995)
State v. Rodriguez
828 P.2d 636 (Court of Appeals of Washington, 1992)
State v. Stenson
940 P.2d 1239 (Washington Supreme Court, 1997)
State v. Jacobsen
477 P.2d 1 (Washington Supreme Court, 1970)
Backlund v. BOARD OF COMMISSIONERS OF KING CTY. HOSP. DIST. NO. 2
724 P.2d 981 (Washington Supreme Court, 1986)
State v. DeBolt
808 P.2d 794 (Court of Appeals of Washington, 1991)
First United Methodist v. Hearing Examiner
916 P.2d 374 (Washington Supreme Court, 1996)
State v. Meacham
612 P.2d 795 (Washington Supreme Court, 1980)
State v. Russell
882 P.2d 747 (Washington Supreme Court, 1994)
State v. Pelkey
745 P.2d 854 (Washington Supreme Court, 1987)
State v. Jackson
554 P.2d 1347 (Washington Supreme Court, 1976)
State v. Vangerpen
888 P.2d 1177 (Washington Supreme Court, 1995)
State v. Thomas
852 P.2d 1130 (Court of Appeals of Washington, 1993)

Cite This Page — Counsel Stack

Bluebook (online)
State Of Washington, V. Jason Dominguez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-jason-dominguez-washctapp-2025.