State of Washington v. Christopher Edward Dodson

No. 39755-6-III (Wash. Ct. App. Feb. 10, 2026) · Court of Appeals of the State of Washington, Division Three · February 10, 2026 · No. 39755-6-III

Summary

The Washington Court of Appeals, Division Three, holds that a testifying forensic scientist violated the confrontation clause by presenting blood-test results based on testing and analysis performed by a nontestifying scientist. Applying Smith v. Arizona and State v. Hall-Haught, the court concludes that the error was harmless and affirms Christopher Dodson’s vehicular homicide conviction. The court declines to address the challenge concerning testing blood stored in an expired vial because Dodson did not raise that ground for exclusion at trial.

Holdings

  1. The toxicology results were testimonial because Daniel performed the tests for the purpose of presenting information in a criminal prosecution and the results inculpated Dodson.
  2. Gingras's testimony about the THC results from vial A and the THC and methamphetamine results from vial B conveyed testimonial hearsay and violated Dodson's confrontation-clause rights because Daniel, not Gingras, performed the relevant testing and possessed percipient knowledge of the testing process.
  3. The confrontation-clause violation was harmless beyond a reasonable doubt and did not require reversal of Dodson's conviction.
  4. The court would not review Dodson's challenge to the admission of results from expired vial B because he did not raise the statutory or Frye admissibility theories in the trial court.
  5. The $500 victim penalty assessment had to be stricken because Dodson was indigent and the amended statute applied to this nonfinal direct appeal.

Questions Presented

  1. Whether Gingras's testimony about THC and methamphetamine results generated through Daniel's testing conveyed testimonial hearsay and violated the federal and state confrontation clauses.
  2. Whether any confrontation-clause violation was harmless beyond a reasonable doubt.
  3. Whether Dodson preserved a challenge to the admission of test results from expired vial B under RCW 46.61.506(3) and Frye.
  4. Whether the $500 victim penalty assessment had to be stricken because Dodson was indigent under the 2023 statutory amendment.

Disposition

affirmed

Cases Cited (27)

  • Smith v. Arizona, 602 U.S. 779, 144 S. Ct. 1785, 219 L. Ed. 2d 420 (2024)(followed)
  • State v. Hall-Haught, 4 Wn.3d 810, 569 P.3d 315 (2025)(followed)
  • State v. Lui, 179 Wn.2d 457, 315 P.3d 493 (2014)(abrogated in part)
  • City of Seattle v. Wiggins, 23 Wn. App. 2d 401, 515 P.3d 1029 (2022)(followed)
  • Crawford v. Washington, 541 U.S. 36, 51, 124 S. Ct. 1354, 158 L. Ed. 2d 177 (2004)(followed)
  • Davis v. Washington, 547 U.S. 813, 822-23, 126 S. Ct. 2266, 165 L. Ed. 2d 224 (2006)(followed)
  • Melendez-Diaz v. Massachusetts, 557 U.S. 305, 307, 311, 318, 329, 129 S. Ct. 2527, 174 L. Ed. 2d 314 (2009)(followed)
  • Bullcoming v. New Mexico, 564 U.S. 647, 651-52, 661, 131 S. Ct. 2705, 180 L. Ed. 2d 610 (2011)(followed)
  • Maryland v. Craig, 497 U.S. 836, 845, 851, 110 S. Ct. 3157, 111 L. Ed. 2d 666 (1990)(followed)
  • State v. Foster, 135 Wn.2d 441, 456, 957 P.2d 712 (1998)(followed)

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