State v. Anderson, 254 P.3d 815

Anderson was charged with first-degree child molestation for alleged sexual contact with M.A.E. and the State sought to offer two prior uncharged offenses involving C.C.S. and another child, K.R.P.; RCW 10.58.090(2) notice given to introduce these prior acts.
C.C.S. disclosed the molestation to a school counselor, police, and during a forensic interview, leading to investigation and charges against Anderson.
C.C.S. was later examined by nurse Nancy Young at a Sexual Assault Clinic; Young was aware of C.C.S.’s prior statements before examination.
Young testified about C.C.S.’s statements to the detective and the corroborating history, but did not obtain information directly from C.C.S.; the record is unclear on timing between the detective interview and the clinic visit.
The trial admitted Young’s statements about C.C.S.’s statements as part of the medical examination; jury received testimony from M.A.E. and evidence of prior misconduct with K.R.P.; the jury was instructed to determine elements of the current offense independent of prior misconduct.
The Court of Appeals affirmed, and, on review, the Washington Supreme Court found the nurse’s testimony to be testimonial and concededly error, but held the error harmless based on overwhelming remaining evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admitting nurse Young’s testimony about C.C.S.’s statements was harmless error.	Anderson argues admission violated Confrontation Clause as testimonial.	State concedes statements were testimonial but argues overwhelming evidence renders error harmless.	Harmless error; conviction upheld on harmlessness grounds.

Crawford v. Washington, 541 U.S. 36 (2004) (confrontation clause; testified statements require cross-examination when testimonial)
State v. Watt, 160 Wash.2d 626 (2007) (harmless-error standard uses overwhelming untainted evidence)
State v. Guloy, 104 Wash.2d 412 (1985) (overwhelming untainted evidence test for harmlessness)