State v. Falk

Defendant Ronald Falk was convicted by jury of one count of possessing and one count of delivering heroin. On appeal he assigns error to the trial court's refusal to grant a mistrial, urging: (1) that the State had not disclosed defendant's prior incriminating statement; (2) that no CrR 3.5 hearing was conducted to determine voluntariness of the statement; and (3) introduction of the statement was improper rebuttal. We find no error and affirm.

Utilizing a confidential informant and undercover agents, the State supplied money to defendant to purchase heroin. Following an actual delivery of the…