State Of Washington v. Tanya James-buhl, 198 Wash. App. 288

Tanya James-Buhl, a junior high school teacher, was charged with three counts for failing to report suspected child abuse after her three daughters told her their stepfather had touched them inappropriately.
The disclosures to James-Buhl occurred in her capacity as a parent; the daughters were not her students.
The trial court dismissed the charges, ruling RCW 26.44.030(1)(a) (mandatory reporters including teachers) applies only to information obtained in the course of employment and that James-Buhl instead fell under RCW 26.44.030(1)(d) (adults residing with children), which requires reporting only for "severe abuse."
The State appealed, arguing subsection (1)(a) contains no course-of-employment limitation and applies to information obtained in any context when there is "reasonable cause."
The Court of Appeals considered statutory text, context, and legislative history and reversed the dismissal, holding subsection (1)(a) imposes a reporting duty in all circumstances for the listed professionals.
The court declined to decide whether, on the facts, James-Buhl actually had "reasonable cause" to believe her children were abused because she had not preserved that factual sufficiency challenge under CrR 8.3.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RCW 26.44.030(1)(a) is limited to information obtained in the course of employment	(State) Subsection (1)(a) contains no course-of-employment limitation and requires mandatory reporters (including teachers) to report whenever they have reasonable cause, regardless of where they learned the information	(James-Buhl) A teacher’s duty under (1)(a) should be limited to suspected abuse learned in the course of employment; disclosures to her as a parent trigger the separate, narrower duty under (1)(d)	The plain text and context show no course-of-employment limitation in (1)(a); the duty applies in all circumstances for persons listed in (1)(a)
Whether the court should resolve whether James-Buhl had reasonable cause to report	(State) N/A at trial (argument not raised below)	(James-Buhl) Even if (1)(a) applies, she lacked reasonable cause to be required to report	Court declined to consider; factual sufficiency (reasonable cause) is a factual issue not preserved under CrR 8.3 on this record

State v. Evans, 177 Wn.2d 186 (statutory interpretation principles)
State v. Larson, 184 Wn.2d 843 (plain meaning and context govern legislative intent)
State v. Chester, 133 Wn.2d 15 (court will not add language to an unambiguous statute)
State v. Roggenkamp, 153 Wn.2d 614 (avoid interpretations that render statutory language superfluous)
Beggs v. Dep’t of Social & Health Servs., 171 Wn.2d 69 (civil liability implications of mandatory reporting statutes)
State v. Groom, 133 Wn.2d 679 (courts must apply enacted statutory text even if harsh)
State v. Peeler, 183 Wn.2d 169 (courts should not second-guess legislative policy choices)