Austin v. United States

CourtDistrict of Columbia Court of Appeals
DecidedApril 20, 2023
Docket21-CF-0187
StatusPublished

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Austin v. United States, (D.C. 2023).

Opinion

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DISTRICT OF COLUMBIA COURT OF APPEALS

No. 21-CF-0187

EDDIE AUSTIN, APPELLANT,

V.

UNITED STATES, APPELLEE.

Appeal from the Superior Court of the District of Columbia (2019-CF3-011203)

(Hon. Judith A. Smith, Trial Judge)

(Submitted Sept. 27, 2022 Decided April 20, 2023)

Mindy Daniels was on the brief for appellant.

Matthew M. Graves, United States Attorney, and Chrisellen R. Kolb, Elizabeth H. Danello, Jeffrey Wojcik, Pravallika Palacharla, and Emmanuel C. Hampton, Assistant United States Attorneys, were on the brief for appellee.

Before DEAHL and HOWARD, Associate Judges, and GLICKMAN, ∗ Senior Judge.

∗ Judge Glickman was an Associate Judge of the court at the time of submission. He began his service as a Senior Judge on December 21, 2022. 2

DEAHL, Associate Judge: Eddie Austin appeals his convictions for carjacking

and related offenses after he drove off in his friend Ashley Thomas’s car. Thomas

was holding onto the car’s door when Austin started driving away, and she was

dragged behind the car for some time, causing her various injuries, before she let go.

On appeal, Austin advances five different arguments, two of which we preview now.

First, Austin argues that his convictions for unauthorized use of a vehicle and

first-degree theft of a vehicle should merge. Our precedents once directed that very

result, but they did so under a fact-based approach to merger that we have since

rejected, and in any event there have since been material statutory amendments to

D.C. Code § 22-3203 that compel a different result. Those amendments instruct that

“[a] person may be convicted of any combination of theft, . . . unauthorized use of a

vehicle,” and a variety of other offenses “for the same act or course of conduct,”

making clear that the offenses do not merge, so that our precedents once holding

otherwise have been superseded by statute. We therefore reject Austin’s argument

that these offenses merge.

Second, Austin argues that the government presented insufficient evidence to

convict him of assault with significant bodily injury, which we have defined as injury

requiring medical treatment necessary “to prevent long-term physical damage, 3

possible disability, disfigurement, or severe pain,” or similar maladies. In re R.S., 6

A.3d 854, 859 (D.C. 2010); see D.C. Code § 22-404(a)(2). The government

presented evidence that Thomas had suffered scarring on a large portion of her back,

which was still visible to the jury at trial a year later. We conclude that this suffices

to show significant bodily injury.

We therefore affirm the majority of Austin’s convictions, though we remand

and direct the trial court to vacate one of his convictions (as it merges with another)

and resentence Austin (because it sentenced him for assault with intent to rob while

armed, where the jury convicted him only of the unarmed version of that offense).

I.

A.

Eddie Austin and Ashley Thomas were friends. They had known each other

for many years and would hang out regularly. Thomas would sometimes ask Austin

to “do [] little stuff for [her],” like paying for her to get her hair and nails done, or to

get her brakes fixed. On the day in question, Thomas picked Austin up in her car

and drove to the beauty supply store, where Thomas testified that Austin “was

supposed to buy [her] some hair.” But after the pair exited the car, they got into a 4

heated argument and Thomas told Austin not to get back into her car, though he did

so anyway. Thomas then drove somewhere in order to buy marijuana, all the while

asking Austin to leave. After Thomas picked up the marijuana, she drove toward

her cousin’s house. As they were driving along the highway, Thomas heard Austin

on the phone telling somebody, “I’m about to steal this bitch.” Thomas understood

that to be slang for Austin saying he was about to punch her.

Thomas pulled over onto the median and got out of the car but, as she was

getting out, she remembered that she had left her keys in the ignition. She tried to

get back into the car through the driver’s door, but Austin had started climbing from

the passenger seat into the driver’s seat and pushed her out. Austin then started to

drive off, though Thomas managed to hold on to the driver’s side door handle.

Thomas clung to the door as Austin drove down the highway, with cars rushing past

her. She eventually let go, rolled over onto the median, got up, and stumbled to the

side of the highway.

Three woman were driving by at the time and saw the events unfold. They all

stopped and spoke to Thomas, and one of them called 9-1-1. An ambulance arrived

and the paramedics treated Thomas on the side of the road. Thomas had scrapes on

her arms, wrists, and knee, and had lost a decent-sized patch of skin on a portion of 5

her lower back, leaving a raw spot on her back about the size of a paper plate. The

ambulance then drove Thomas to hospital, where she was prescribed pain

medication for her injuries. Thomas’s car was later found about half a mile from

Austin’s residence.

B.

Austin was charged with seven counts: carjacking, D.C. Code § 22-2803(a);

assault with intent to commit robbery, D.C. Code § 22-401; assault with significant

bodily injury while armed, D.C. Code §§ 22-404(a)(2), -4502; assault with a

dangerous weapon (motor vehicle), D.C. Code § 22-402; first-degree theft, D.C.

Code §§ 22-3211, -3212(a); unauthorized use of a vehicle, D.C. Code § 22-3215;

and threats to do bodily harm, D.C. Code § 22-407.

Austin’s defense was mistaken identification. Thomas identified Austin as

the driver at trial and she had identified him with “a hundred percent certain[ty]” in

a photo array before trial. But Thomas was the only witness to identify Austin, and

Austin posited some reasons to doubt the reliability of her identification. Thomas

had testified that she had memory issues linked to a previous car accident that had

left her in a coma for two months, and she also smoked marijuana regularly,

including before testifying in court. There were inconsistencies between Thomas’s 6

testimony and those of other witnesses, including that one witness heard Thomas

say, directly after the incident, that she did not know the driver. There were also

internal inconsistencies in Thomas’s testimony, including the length of time she had

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