State v. Pearson, 321 P.3d 1285

On Sept. 22, 2011 a confidential informant bought hydrocodone from Richard L. Pearson at his Yakima trailer; Pearson was charged with delivery of a controlled substance with a special allegation that the delivery occurred within 1,000 feet of a school bus stop.
Yakima County GIS director Michael Martian testified that county maps show school bus stop locations obtained annually from school districts (latitude/longitude points submitted to the State), and Martian produced a map centered on Pearson’s address with a 1,000-foot radius.
The GIS map showing bus stops was admitted at trial; no school district official testified to the bus stop locations or their use on the date of the offense.
The jury found Pearson guilty and found the special allegation true (delivery within 1,000 feet of a school bus stop).
The trial court vacated the jury’s special verdict, concluding the map’s use implicated the Confrontation Clause because the bus-stop data derived from school-district declarants who did not testify; the State appealed.
The appellate court affirmed, holding the county map reflected information prepared for potential prosecutorial use (testimonial), and without the school-district declarant being available for cross-examination the map was inadmissible to support the enhancement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the jury’s special verdict that the delivery occurred within 1,000 feet of a school bus stop was supported by admissible evidence	State: GIS map (a county-produced map containing school-submitted bus-stop points) was admissible and established the statutorily required location evidence	Pearson: GIS map was insufficient because no school-district official who provided the bus-stop data testified; Confrontation Clause bars admitting testimonial out-of-court statements without cross-examination	The map was testimonial (prepared for potential prosecutorial use); because the school-district declarant did not testify and was not shown unavailable, admission violated the Confrontation Clause; vacatur of the special verdict affirmed

Crawford v. Washington, 541 U.S. 36 (2004) (testimonial hearsay requires confrontation/right to cross-examination)
Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (documents/tests prepared for use in prosecution are testimonial)
State v. Jasper, 174 Wn.2d 96 (2012) (discusses Crawford and testimonial definition under state law)