Defendant's Prior Statements Admissibility In Washington

In Washington, prior statements made by a defendant are admissible at trial for purposes of impeachment." State v. Simpson, 95 Wn.2d (1980) at 179-80 (citing State v. Peele, 10 Wn. App. 58, 67, 516 P.2d 788 (1973)). The plurality concluded that "under these circumstances, we discern both a continuing policy basis and firm state constitutional grounds for adherence to the automatic standing rule. The rule is already established under our state constitution and has served our state well for 17 years . . . ." Simpson, 95 Wn.2d at 181 (citing State v. Michaels, 60 Wn.2d at 646-47). Although there may be ample support in this statement to conclude that our state constitution requires automatic standing, we agree with the State that this is not a proper case to apply automatic standing. In State v. Michaels, 60 Wn.2d 638, 646-47, 374 P.2d 989 (1962), the Court acknowledged that application of automatic standing is proper where: (1) "the defendant is legitimately on the premises where a search occurred"; (2) "the fruits of the search are proposed to be used against him." Michaels, 60 Wn.2d at 646-47.