State v. Warner

In State v. Warner, 125 Wn.2d 876, 889 P.2d 479 (1995), the Court held that a criminal defendant may not claim negligent prosecutorial delay stemming from the failure to promptly report suspected child abuse, as required by RCW 26.44.030, because the reporting requirement was intended to benefit victims of child abuse, not abusers. Warner, 125 Wn.2d at 891. The State's reliance on Warner is misplaced. First, Warner dealt with a different statutory provision, the duty to report child abuse, not the duty to investigate allegations once they have been reported. Id. Second, Warner did not involve a claim by a parent or family member. Id. at 881.