State of Washington v. Laura Elaine McCarver

CourtCourt of Appeals of Washington
DecidedJanuary 30, 2025
Docket39685-1
StatusUnpublished

This text of State of Washington v. Laura Elaine McCarver (State of Washington v. Laura Elaine McCarver) 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. Laura Elaine McCarver, (Wash. Ct. App. 2025).

Opinion

FILED JANUARY 30, 2025 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) ) No. 39685-1-III Respondent, ) ) v. ) ) UNPUBLISHED OPINION LAURA ELAINE MCCARVER, ) ) Appellant. ) ) FEARING, J. — In this appeal, Laura McCarver claims the superior court violated

her due process rights because she lacked the opportunity to cross-examine State

witnesses and because the court considered unadmitted hearsay evidence when revoking

her Drug Offender Sentencing Alternative (DOSA). We reject the appeal because

McCarver, before the superior court, never challenged the hearsay evidence or

complained about the opportunity to question witnesses. Nor does McCarver show

manifest constitutional error.

FACTS

This appeal arises from Laura McCarver’s DOSA. On January 13, 2022,

McCarver pled guilty to assault of a child in the third degree, with a special domestic No. 39685-1-III State v. McCarver

violence allegation, as an accomplice (count I); first-degree criminal mistreatment (count

II); two counts of criminal contempt for violating her release conditions (counts III and

IV); and delivery of methamphetamine as an accomplice (count V). The underlying facts

behind the crimes bear little relevance to this appeal. McCarver had no prior felony

convictions. The State agreed to recommend a prison-based DOSA.

During the 2022 sentencing hearing, the State’s attorney commented that Laura

McCarver, the mother of children, suffers from controlled substance dependency and she

acknowledges a need for treatment. Defense counsel echoed that McCarver would

benefit from treatment. McCarver personally added:

There’s been a period in my life that I’ve struggled with addiction, which has led me to always not making the right choices. But I do know for my future and for my children’s future that it’s work that gives opportunity to improve myself. I really want to take this time and focus on a new drug treatment or mental health services so I can become the best version of myself and the best mother to my children, who deserve it.

Report of Proceedings (RP) at 31.

The superior court accepted the State’s recommendation and imposed a DOSA

sentence consisting of three years of prison followed by three years of community

custody under the supervision of the Department of Corrections (DOC). When imposing

the term, the court intoned:

Ms. McCarver, you may notice already—you probably do from talking to [your lawyer], but hopefully you understand that the standard range on Count 2 was up to 82 months. And if—I mention this just because 2 No. 39685-1-III State v. McCarver

when a—when one dodges a bullet, it’s useful to know what kind of bullet. That was an 82-month bullet that you dodged by getting this DOSA.

RP at 36-37.

On December 1, 2022, DOC, apparently early, released Laura McCarver from

prison, at which time she began the community custody sentence segment. Her

community custody conditions included remaining free from controlled substances and

submitted to urinalysis (UA).

According to DOC records, Laura McCarver submitted a urinalysis on January 5,

2023, which tested positive for methamphetamine. Another UA, submitted on January

17, 2023, also tested positive for methamphetamine. McCarver admitted to using the

drug in both instances. In response, DOC placed McCarver in a thirty-day inpatient drug

treatment facility, from which she was released on February 23, 2023.

On March 15, 2023, Laura McCarver submitted another UA, which again tested

positive for methamphetamine. Nevertheless, this time, she denied using any controlled

substances. On March 21, 2023, McCarver provided two UAs, one at 11:00 a.m. and

another at 12:40 p.m. The first urinalysis tested positive for methamphetamine and the

second for opiates. McCarver again denied using controlled substances.

DOC sent the two March 15 UA samples to a laboratory for further testing and

confirmation of the presence of controlled substances. On March 22, 2023, DOC

submitted a report titled “Court – Special” to the Douglas County Superior Court and

3 No. 39685-1-III State v. McCarver

Prosecuting Attorney’s Office, outlining McCarver’s repeated failure to comply with the

terms of her DOSA sentence.

PROCEDURE

On March 22, 2023, the State moved to revoke Laura McCarver’s DOSA. The

UA results had yet to be confirmed by the laboratory.

At the initial DOSA revocation hearing on April 3, 2023, the State’s attorney

informed the court that Laura McCarver had took controlled substances since her

emancipation from incarceration in December 2022 and thus serially violated the terms of

her release. The State added that, after a second violation, DOC enrolled her in a month-

long inpatient treatment program, but she continued to take unlawful substances after

release from the treatment. The court inquired about whether the State had received

results from the independent lab testing. The State answered that a DOC supervisor

would confirm the results later that day. The State argued, however, that DOC’s test

results met the evidentiary standard to revoke McCarver’s DOSA sentence.

At the April 3, 2023 hearing, Laura McCarver’s counsel requested a continuance

in order for the parties to receive the additional urinalysis results. The court agreed to

continue the hearing for a week.

By April 11, 2023, when the DOSA revocation hearing resumed, the State had yet

to receive test results from the independent laboratory. At the resumed hearing, the State

recounted the details of Laura McCarver’s convictions and her actions since her release: 4 No. 39685-1-III State v. McCarver

On January 5th, 2023, she [Laura McCarver] tested positive for methamphetamines when she went to her DOC officer. There was a sanction, which required her to report twice weekly for a period of time. And then on January 17, 12 days later, she tested positive for methamphetamine again when she went to DOC. And on January 24, she went immediately to ABHS inpatient treatment—I assume in Wenatchee—and was released from there after about 30 days on February 23rd, 2023. [Defense counsel] was kind enough to provide us with the evaluation and monthly reports from ABHS/The Center for Drug and Alcohol Treatment, which documents her history there. …. In—so February 23rd, she was released. And on March 15, she was positive for methamphetamines again. This time she went to jail for three days as a part of a sanction. She was once again positive for methamphetamine and opiates on March 21st. So she had been in custody presumably from March 15 or 16 and then got out and then on March 21st, was positive. She started her outpatient treatment specifically on March 1st. And on March 13, she was absent and she had an individual session on March 14. And I say these dates because on March 15, she had a dirty UA. And that’s the one that just—just before she went to jail for three days.

RP at 57-58.

At the April 11 hearing, the State asked the superior court to revoke the DOSA

sentence because of the many positive urinalysis test results. According to the State,

Laura McCarver had chosen to live a lifestyle that entailed drug abuse.

During the April 11 revocation hearing, the State read from Laura McCarver’s

drug treatment assessment and progress report from April 2023. In response, defense

counsel moved for admission of the full report rather than the State selecting favorable

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

Related

Yakus v. United States
321 U.S. 414 (Supreme Court, 1944)
Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
United States v. Olano
507 U.S. 725 (Supreme Court, 1993)
State v. Lynn
835 P.2d 251 (Court of Appeals of Washington, 1992)
State v. Nelson
697 P.2d 579 (Washington Supreme Court, 1985)
Smith v. Shannon
666 P.2d 351 (Washington Supreme Court, 1983)
State Ex Rel. Woodhouse v. Dore
416 P.2d 670 (Washington Supreme Court, 1966)
State v. Scott
757 P.2d 492 (Washington Supreme Court, 1988)
State v. McFarland
899 P.2d 1251 (Washington Supreme Court, 1995)
State v. Riley
846 P.2d 1365 (Washington Supreme Court, 1993)
State v. Emery
278 P.3d 653 (Washington Supreme Court, 2012)
State v. Weber
149 P.3d 646 (Washington Supreme Court, 2006)
State v. Dahl
990 P.2d 396 (Washington Supreme Court, 1999)
In re Pers. Restraint of Schley
421 P.3d 951 (Washington Supreme Court, 2018)
State v. Dahl
139 Wash. 2d 678 (Washington Supreme Court, 1999)
State v. Weber
159 Wash. 2d 252 (Washington Supreme Court, 2006)
State v. O'Hara
167 Wash. 2d 91 (Washington Supreme Court, 2009)
State v. Guzman Nuñez
174 Wash. 2d 707 (Washington Supreme Court, 2012)
State v. Strine
293 P.3d 1177 (Washington Supreme Court, 2013)
State v. Nunez
160 Wash. App. 150 (Court of Appeals of Washington, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
State of Washington v. Laura Elaine McCarver, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-laura-elaine-mccarver-washctapp-2025.