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Introduction

The Washington Supreme Court’s decision in State v. Stearns addresses a critical issue in criminal trials: when can the State introduce evidence of a defendant’s prior bad acts? The case centers on the application of ER 404(b) Washington evidence rules and clarifies how courts must evaluate the admissibility of prior misconduct.

This decision is particularly important for criminal defense and prosecution alike because it reinforces the limits—and permissible uses—of prior acts evidence in Washington courts.

Background of State v. Stearns

The case arises from the 1998 rape and murder of Crystal Williams in Seattle. Williams was found deceased near a public restroom with significant physical injuries and evidence of sexual assault. Years later, DNA evidence connected John Ray Stearns to the crime. 

At trial, the State introduced evidence that Stearns had committed multiple prior violent sexual assaults in the same neighborhood. These incidents occurred in 1981, 1989, and 1999, and in each instance, Stearns had either pleaded guilty or been convicted. 

The trial court admitted this evidence under ER 404(b), and the jury ultimately convicted Stearns of first-degree murder.

What Is ER 404(b) Washington Evidence?

General Rule

Under Washington Evidence Rule 404(b), evidence of prior bad acts is generally not admissible to prove a person’s character in order to show they acted consistently with that character.

Exceptions

However, such evidence may be admitted for specific purposes, including:

  • Proving identity
  • Showing a common scheme or plan
  • Establishing motive or intent

Courts must carefully balance the probative value of the evidence against its potential for unfair prejudice.

Admission of Prior Sexual Assaults

The central issue was whether the trial court properly admitted evidence of Stearns’ prior sexual assaults under ER 404(b).

The Court of Appeals reversed the conviction, concluding that the evidence was improperly admitted. However, the Washington Supreme Court reviewed whether that decision correctly applied the law.

Washington Supreme Court Analysis

Deference to Trial Courts

A key issue was the standard of review. The Supreme Court emphasized that evidentiary rulings—like those under ER 404(b)—are reviewed for abuse of discretion, not de novo.

The Court criticized the Court of Appeals for failing to give proper deference to the trial court’s decision-making.

Proper Use of ER 404(b) Evidence

The Supreme Court focused on whether the prior assaults were admissible for a legitimate purpose, such as:

  • Establishing a pattern of behavior
  • Demonstrating identity through similar conduct

The prior assaults shared similarities in location and nature, which supported their admissibility for non-propensity purposes.

Rejection of Improper Reasoning

The Court also addressed concerns that the appellate court relied on incorrect assumptions about sexual assault cases and improperly substituted its judgment for that of the trial court. 

Key Holding

The Washington Supreme Court ultimately held that the Court of Appeals erred in reversing the conviction based on the ER 404(b) ruling.

The decision reaffirmed that:

  • Trial courts have broad discretion in admitting evidence
  • Appellate courts must not reweigh evidence
  • Prior bad acts may be admissible when used for a proper, limited purpose

Why This Case Matters

Clarifies ER 404(b) in Washington

State v. Stearns reinforces that ER 404(b) is not an absolute bar to prior acts evidence. Instead, it requires careful judicial analysis and proper limiting instructions.

Strengthens Trial Court Authority

The case underscores that appellate courts must respect the trial court’s role unless there is a clear abuse of discretion.

Implications for Criminal Defense

For defendants, this case highlights:

  • The importance of challenging ER 404(b) evidence early
  • The difficulty of overturning evidentiary rulings on appeal
  • The powerful impact prior acts evidence can have on juries

ER 404(b) Washington Evidence: Practical Takeaways

1. Prior Acts Can Be Admitted—But Only for Limited Purposes

Courts must identify a specific, non-propensity purpose.

2. Similarity Matters

The more similar the prior acts, the more likely they are admissible.

3. Trial Court Discretion Is Broad

Appellate courts rarely overturn these decisions without clear error.

Call to Action

If you are facing criminal charges or believe improper evidence was used in your case, legal guidance is essential.

Contact Blanford Law today at ken@blanfordlaw.com or 253-720-9304 for guidance on your legal matter.

Additional Resources

Internal Links

RCW 10.58.090 Unconstitutional: State v. Gresham
Analyzes a Washington case addressing unconstitutional evidentiary restrictions and their impact on criminal trials.
https://blanfordlaw.com/rcw-10-58-090-unconstitutional-state-v-gresham/

ER 613 Prior Statements in Washington
Explains how prior inconsistent statements can be used to challenge witness credibility in court.
https://blanfordlaw.com/er-613-prior-statements/

Frederick Coe Case and Evidence Issues
Reviews evidentiary challenges in a high-profile Washington criminal case involving forensic and testimonial evidence.
https://blanfordlaw.com/frederick-coe-case-evidence/

Washington Evidence Rule 412 in Sexual Offense Cases
Discusses limits on admissibility of a victim’s past conduct and how courts balance fairness and privacy.
https://blanfordlaw.com/navigating-washington-evidence-rule-412-implications-for-sexual-offense-cases-in-civil-proceedings/

ER 609 Impeachment by Prior Convictions
Breaks down how prior convictions may be used to impeach a witness’s credibility in Washington courts.
https://blanfordlaw.com/er-609-impeachment/