State Of Washington, V Gregoria Ivan Layna, 49171-1

Owner Oberst reported her motor home stolen from a barn; she had not been to the property for weeks and could not fix the exact theft date.
Witness Anderson saw a motor home on a dirt road and observed Layna in or near it; she saw it later coasting; dates she recalled varied.
Liz Allen (a prior seller) saw the motor home parked at a house on Feb. 26 with its plate covered and reported it.
Deputy Rasmussen located and impounded the motor home; it was hotwired, battery dead, interior gutted; no barn property was found in the vehicle or on Layna.
Layna was charged with burglary, theft of a motor vehicle, possession of a stolen vehicle, and trafficking in stolen property (1st and 2nd degree). Jury convicted on theft of a motor vehicle, possession of a stolen vehicle, and trafficking in the second degree; acquitted of burglary and trafficking in the first degree.
At sentencing the court imposed $1,000 discretionary LFOs without a full inquiry into Layna’s present/future ability to pay; payments were deferred two years and set at $50/month.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for theft of a motor vehicle	State: possession, hotwiring, and presence at locations supports theft conviction	Layna: State failed to prove he wrongfully obtained or exercised unauthorized control; no evidence he took it from the barn or when	Reversed — evidence insufficient to prove Layna stole the motor home
Sufficiency of evidence for trafficking in stolen property (2d deg.)	State: evidence of concealment, attempts to sell, and possession supports trafficking	Layna: No proof of intent to sell or dispose	Affirmed — sufficient evidence a jury could infer intent to dispose/sell (trafficking)
Admission of CAD (911) call logs / Confrontation Clause	State: CAD logs are admissible and corroborative	Layna: Admission violated Sixth Amendment confrontation right because dispatchers (who prepared logs) did not testify	Admission was constitutional error (testimonial hearsay) but harmless beyond a reasonable doubt given overwhelming other evidence
Imposition of discretionary LFOs without inquiry	State: discretionary LFOs appropriate	Layna: Sentencing court failed to conduct individualized inquiry into present/future ability to pay as required by Blazina	Reversed — court must perform Blazina-style inquiry and reconsider discretionary LFOs on remand

State v. Salinas, 119 Wn.2d 192 (1992) (standard for sufficiency of the evidence review)
State v. Ague–Masters, 138 Wn. App. 86 (2007) (deference to jury on credibility)
State v. Rich, 184 Wn.2d 897 (2016) (de novo review of sufficiency challenges)
State v. Koslowski, 166 Wn.2d 409 (2009) (testimonial statement/confrontation analysis)
State v. Powers, 124 Wn. App. 92 (2004) (CAD call logs are testimonial)
State v. Franklin, 180 Wn.2d 371 (2014) (harmless error standard for constitutional errors)
State v. Watt, 160 Wn.2d 626 (2007) (presumption that constitutional error is prejudicial)
State v. Blazina, 182 Wn.2d 827 (2015) (requirement for individualized inquiry into ability to pay before imposing discretionary LFOs)
State v. Clark, 191 Wn. App. 369 (2015) (standard of review for imposition of discretionary LFOs)