State ex rel. McDonald v. Whatcom County Dist. Court
In State ex rel. McDonald v. Whatcom County Dist. Court, 92 Wn.2d 35, 36-37, 593 P.2d 546 (1979) the investigating officer arrested the driver, who was involved in a one-car accident, at the hospital where the driver was taken for treatment. Id. at 36.
Observing the statute was in derogation of the common law rule prohibiting a misdemeanor arrest for crimes not committed in the officer's presence we held that it must be strictly construed, id. at 37, to prohibit the investigating officer from making the arrest at the hospital because the arrest did not take place "'at the scene of a motor vehicle accident.'" Id.