State Of Washington v. Sean Crocker, 483 P.3d 115

Video showed Crocker giving a THC "dab" to a student; students admitted leaving school to go to Crocker’s house to "get high."
Two weeks later police executed a search warrant at Crocker’s home and found marijuana in various forms, THC concentrate, drug ledgers, scales, baggies, and packaging material near Crocker’s bedroom window.
Officers recovered samples from Crocker’s bedroom (a leaf sample labeled "Durango" and a THC concentrate sample) that were lab tested for THC concentration.
Seven current or former high-school students testified they bought marijuana and/or dabs from Crocker at his bedroom window, mostly on multiple occasions.
At retrial Crocker was convicted of six counts of distribution of marijuana to a minor and one count of possession with intent to deliver; he appealed arguing the State failed to prove the distributed substances were legally "marijuana."

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that the substances distributed were "marijuana" (THC > 0.3%)	Lab testing of samples recovered from Crocker’s bedroom plus circumstantial evidence tied the tested material to the distributions and proved marijuana.	The State failed to prove the actual items given to minors were marijuana; random sample testing did not establish nexus to what was distributed.	Affirmed — viewing evidence in light most favorable to the State, lab results together with testimony about THC, repeat customers, paraphernalia, ledgers, and business indicia were sufficient.
Whether Crowder requires direct sample-to-sample nexus or expert bridging testimony on THC potency	The State contended that expert and detective testimony about THC thresholds and typical potencies, plus business context and repeat-customer evidence, supplied the necessary link without direct comparison.	Crocker argued Crowder requires either a tested sample that can be tied directly to the distributed item or expert evidence to show that typical product sold would exceed 0.3% THC.	Court distinguished Crowder — here experts testified about THC levels (hemp v. marijuana and typical potencies), buyers had significant marijuana experience, and circumstantial evidence supported inference that sold product was marijuana.

State v. Crowder, 196 Wn. App. 861, 385 P.3d 275 (Wash. App. 2016) (reversing where tested sample lacked nexus to distributed material and no expert THC-context evidence was introduced)
State v. Salinas, 119 Wn.2d 192, 829 P.2d 1068 (Wash. 1992) (standard for sufficiency of evidence review)
State v. Thomas, 150 Wn.2d 821, 83 P.3d 970 (Wash. 2004) (deference to trier of fact on credibility and conflicting testimony)
State v. Goodman, 150 Wn.2d 774, 83 P.3d 410 (Wash. 2004) (circumstantial evidence carries same weight as direct evidence)
State v. Caldera, 66 Wn. App. 548, 832 P.2d 139 (Wash. App. 1992) (random sampling of a consistent substance can support inference about the whole)