## Facts

- Dawn Fehring was found dead in her Kirkland apartment, nude near her bed with a bed sheet and T-shirt wrapped around her head and neck.
- Police found blood on the carpet and bloody handprints on the fitted bed sheet; an autopsy attributed death to asphyxiation and identified hymenal tears as the blood source.
- Eric H. Hayden, a building occupant, became a suspect after he could not account for his whereabouts during the relevant time and reported being too intoxicated to remember.
- A latent print examiner chemically processed portions of the fitted sheet containing the clearest bloody prints using amido black dye and rinses designed to increase contrast.
- The examiner still could not see enough detail to make an identification using ordinary viewing methods.
- A police digital-imaging specialist photographed the fabric samples and used computer software to filter out background patterns and colors to make existing ridge detail easier to see.
- Using the enhanced images, the examiner identified sufficient points of comparison on a fingerprint and a palm print to match Hayden.
- After a Frye hearing, the trial court admitted the enhanced-print evidence; a jury convicted Hayden of first-degree felony murder.
- The sentence included a community placement condition requiring a mental health evaluation and treatment.

## Issues

1. Whether digitally enhanced fingerprint and palm print images derived from photographs of bloody prints were inadmissible as novel scientific evidence under the Frye general-acceptance standard.
2. Whether the trial court erred by imposing a community placement condition requiring a mental health evaluation and treatment.

## Decision

- The Court of Appeals affirmed the conviction and sentence.
- The court held the digital enhancement technique satisfied Frye because it was generally accepted in the relevant forensic community and functioned as image clarification rather than creation of new scientific data.
- The court rejected the challenge to the community placement mental health evaluation/treatment condition.

## Legal Principles

- Under Frye, novel scientific evidence is admissible only if the underlying theory and methodology are generally accepted in the relevant scientific community.
- Computer-based enhancement that filters background and improves contrast to make existing fingerprint ridge detail more visible may be treated as an extension of accepted photographic and fingerprint-comparison practices, not a new scientific test.
- When a generally accepted enhancement process does not add, delete, or alter ridge detail, challenges to possible artifacts or over-enhancement ordinarily go to weight and credibility for the jury, not admissibility.
- Sentencing courts may impose community placement conditions, including mental health evaluation and treatment, when authorized and not shown to be reversible error.

## Conclusion

The court affirmed a felony-murder conviction, holding that computer-enhanced images of bloody fingerprints were admissible under Frye as generally accepted, non-altering image clarification, and it upheld a mental health evaluation and treatment condition of community placement.


State v. Hayden, 90 Wash. App. 100, 950 P.2d 1024 (Ct. App. 1998)