In In re Darrow, 32 Wn. App. 803, 649 P.2d 858, 859-61 (Wash. Ct. App. 1982), the father was serving a 10-year sentence in Arizona. 649 P.2d at 859.
The state of Arizona agreed to allow the father to be transported to the state of Washington, but Washington refused to pay for the costs of transportation and custody of the father. Id.
There, the incarcerated father was represented by counsel but did not testify, by telephone or otherwise. Id. The Court of Appeals of Washington held that the father's due process rights were satisfied by allowing him to be represented by counsel and permitting him to participate in the hearing "through alternative methods such as letters, photographs, depositions, or a possible continuance after the State's case in chief to provide additional information." Id. at 861.