State Of Washington v. Stanley Scott Sadler, 73525-0

Background

Sadler posted sexually explicit Craigslist ads seeking a young female; undercover officers (posing as a 15-year-old "Jen") responded.
Sadler exchanged emails and phone calls with the undercover officers; some messages included statements that Jen was 15, others contained a message saying she was "consenting and 18."
Sadler arrived at a planned meeting and was arrested; police found cash on him.
He was charged and convicted of attempted commercial sexual abuse of a minor and communicating with a minor for immoral purposes.
At trial Sadler argued he believed Jen was an adult and sought to admit multiple email chains (some redacted) to support his role‑play/adult‑seeking defense.
He appealed, raising challenges to redactions, admission of opinion testimony, prosecutorial misconduct, sentencing calculations and conditions, evidentiary sufficiency, and other collateral claims.

Issues

Issue	State's Argument	Sadler's Argument	Held
Admissibility / redaction of prior email chains	Redactions removed irrelevant/cumulative sexual-detail passages; admitted portions showed he sought adults and knew of scams	Excluded passages were necessary context and to present his defense (long‑term adult relationship, corroboration)	Court: no abuse of discretion; redacted passages irrelevant or cumulative and did not violate right to present a defense
Admission of undercover officer opinion testimony	Officer testimony described his undercover practice and patterns; did not opine on guilt	Testimony (e.g., "playing a game") was impermissible opinion and suggested Sadler fit an unlawful profile	Court: testimony described investigative practice and behavior, not guilt; admission proper
Prosecutorial misconduct in argument / use of PowerPoint	Arguments and inferences were reasonable; PowerPoint later matched admitted emails	Prosecutor appealed to emotion, disparaged counsel, showed exhibits prematurely and omitted exculpatory excerpts	Court: no flagrant misconduct; comments were reasonable inferences or curable and PowerPoint caused no prejudice
Same‑conduct sentencing (double counting)	Two convictions have different statutory intents and are separate offenses	Offenses arise from same conduct and intent so should be treated as one for sentencing	Court: offenses require different criminal intent; separate for sentencing
Community custody conditions (internet use / sexual contact)	Conditions are crime‑related, supported by record, and narrowly tailored via required evaluation/treatment	Conditions amount to overly broad bans on constitutionally protected conduct and are not sensitively imposed	Court: conditions crime‑related, not total bans; tied to evaluation/treatment and not an abuse of discretion
Sufficiency of evidence	Emails, testimony that Jen said she was fifteen, and undercover calls support that Sadler believed Jen was a minor	Defense points to emails implying age‑play and statements that Jen was 18; claims insufficient evidence	Court: viewing evidence in light most favorable to State, rational juror could find belief Jen was a minor beyond a reasonable doubt
Other collateral claims (outrageous police conduct; vagueness/overbreadth; ineffective assistance)	Police conduct investigative deception allowed; statutes clear; counsel’s choices were strategic	Police conduct was outrageous; statutes vague/overbroad; counsel ineffective for failing to raise these	Court: deception not outrageous; statutes not vague/overbroad as applied; IAC claim unsupported because raised arguments lacked merit

Key Cases Cited

State v. Brockob, 159 Wn.2d 311 (trial court evidentiary rulings reviewed for abuse of discretion)
State v. Vreen, 143 Wn.2d 923 (relevance standard and trial court discretion)
State v. Rohrich, 149 Wn.2d 647 (review for manifest unreasonableness)
State v. Jones, 168 Wn.2d 713 (right to present relevant defense evidence)
State v. Demery, 144 Wn.2d 753 (limits on witnesses opining about guilt)
State v. Thorgerson, 172 Wn.2d 438 (prosecutorial misconduct standard; flagrant/curable error)
In re Glasmann, 175 Wn.2d 696 (prosecutor may argue reasonable inferences; avoid inflammatory appeals)
State v. Coe, 101 Wn.2d 772 (cumulative error doctrine)
State v. Graciano, 176 Wn.2d 531 (same‑conduct sentencing standard; appellate review)
State v. Chenoweth, 185 Wn.2d 218 (distinct statutory intent can distinguish offenses for sentencing)
State v. Bahl, 164 Wn.2d 739 (limitations on constitutional rights in community custody must be narrowly tailored)