In the Matter of the Personal Restraint of: Evaristo Salas, Jr.

CourtCourt of Appeals of Washington
DecidedJune 15, 2023
Docket38570-1
StatusUnpublished

This text of In the Matter of the Personal Restraint of: Evaristo Salas, Jr. (In the Matter of the Personal Restraint of: Evaristo Salas, Jr.) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In the Matter of the Personal Restraint of: Evaristo Salas, Jr., (Wash. Ct. App. 2023).

Opinion

FILED JUNE 15, 2023 In the Office of the Clerk of Court WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

In the Matter of the Personal Restraint of ) ) No. 38570-1-III EVARISTO SALAS, JR., ) ) ) UNPUBLISHED OPINION Petitioner. )

STAAB, J. — Evaristo Salas filed a CrR 7.8 motion to vacate his 1996 conviction

for first degree murder. The superior court denied his motion, and Salas appealed. The

applicable version of CrR 7.8(c) required the superior court to make specific findings

before retaining Salas’ motion and deciding it on the merits. The court did not make

these findings. Thus, we vacate the superior court’s denial of Salas’ motion and, with the

parties’ approval, convert the matter for consideration as a personal restraint petition.

FACTUAL BACKGROUND

In 1996, Salas was convicted of first degree murder. The key witnesses at trial

were Ofelia Gonzalez, the victim’s girlfriend—the only eyewitness to the murder, and

William Bruhn, an informant who claimed that he had overheard Salas confess to the

crime. Over twenty years later, in 2017, an investigation uncovered new evidence

pertaining to the case against Salas, including a recantation from Bruhn and evidence

suggesting that Gonzalez had lied to obtain possession of her truck, where the victim was No. 38570-1-III In re Pers. Restraint of Salas

murdered, prior to police processing it, and that she then had it professionally cleaned,

repaired, and sold. Additionally, Salas’ post-conviction counsel obtained evidence that

Gonzalez may have been hypnotized prior to making her identification of Salas. Finally,

Salas’ post-conviction counsel obtained expert testimony regarding the unreliability of

incentivized witness testimony and eyewitness identifications.

In 2020, Salas filed a CrR 7.8 motion requesting a new trial on the basis of newly

discovered evidence in connection with the evidence described above. Salas also alleged

Brady1 violations.

The trial court retained the CrR 7.8 motion. Salas filed a motion to depose or

compel testimony from Detective James Rivard, the lead investigator in Salas’ case. At

the hearing on the motion, Salas’ counsel indicated after the State’s argument that she

was willing to forego the deposition request if the court was willing to sign an order

subpoenaing Detective Rivard for his appearance at the CrR 7.8 motion for a new trial.

The State opposed calling Detective Rivard as a witness at the CrR 7.8 motion hearing.

The trial court ultimately denied Salas’ post-conviction discovery motion to depose

Detective Rivard.

After the denial, there was discussion regarding whether the trial court would

subpoena Detective Rivard to testify at the CrR 7.8 motion hearing. The trial court

1 Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963).

2 No. 38570-1-III In re Pers. Restraint of Salas

denied that request and made clear that it would not subpoena Bruhn, Gonzalez, or

Detective Rivard to testify at the hearing on the CrR 7.8 motion.

Following the post-conviction discovery motion denial, the State filed its response

to Salas’ CrR 7.8 motion and argued that Bruhn’s conviction was unreliable and that

Salas’ other evidence was not newly discovered.

At the hearing on the CrR 7.8 motion, Salas’ counsel again brought up the issue of

subpoenaing witnesses for the CrR 7.8 motion hearing. The court repeated that it was

denying that request. Salas’ counsel began argument on the CrR 7.8 motion and the court

interrupted to say:

THE COURT: Let me interrupt for just a second. I think—aren’t you in kind of a funny spot right now where, I don’t really want to say I think I lost, but the ruling of September 27 was kind of—took care of today’s hearing?

Isn’t that really what you’re arguing?

Rep. of Proc. (Oct. 27, 2021) at 19-20. Salas’ counsel ultimately agreed with the court

and declined to continue arguing the motion. The court then reiterated its denial of the

motions.

At the conclusion of the hearing, Salas’ counsel requested findings of fact and

conclusions of law and the court replied “[y]ou can do that. I don’t think [the Court of

Appeals] is as interested in it as you might think they are. But I’m glad to entertain if

somebody wants to put some findings together.” Clerk’s Papers at 28. Salas’ counsel

3 No. 38570-1-III In re Pers. Restraint of Salas

stated that she would talk with the State’s counsel and try to get something put together

but that since the State was the prevailing party, they needed to draft findings and

conclusions. The State responded by attempting to make a record of the court’s prior

rulings. The court supplemented the State’s attempt at creating a record and reiterated

some of its rulings and rationale. No written findings of fact or conclusions of law were

entered.

An order denying Salas’ motions for post-conviction discovery and denying his

CrR 7.8 motion for a new trial was entered in January 2022.

Salas appealed.

ANALYSIS

Under the current version of the rule, a trial court can retain a CrR 7.8 motion only

under limited circumstances. The rule provides that a trial court

shall transfer a motion filed by a defendant to the Court of Appeals for consideration as a personal restraint petition unless the court determines that the motion is not barred by RCW 10.73.090 and either (i) the defendant has made a substantial showing that they are entitled to relief or (ii) resolution of the motion will require a factual hearing.

CrR 7.8(c) (emphasis added).

The first determination a trial court must make is whether the motion is barred by

RCW 10.73.090. This statute provides a one-year time bar on collateral attacks of a

criminal defendant’s judgment and sentence. Certain exceptions apply, including newly

discovered evidence. RCW 10.73.100(1).

4 No. 38570-1-III In re Pers. Restraint of Salas

In this case, the trial court concluded that Sala’s newly discovered evidence

provided an exception to the one-year time bar, but did not make any findings to support

this conclusion. Notably, the analysis in determining whether newly discovered evidence

is sufficient to provide an exception to the time bar, and whether newly discovered

evidence is sufficient to make a substantial showing of relief is very similar.

To meet the procedural and substantive requirement, the petitioner must

demonstrate that the newly discovered evidence: “‘(1) will probably change the result of

the trial; (2) was discovered since the trial; (3) could not have been discovered before

trial by the exercise of due diligence; (4) is material; and (5) is not merely cumulative or

impeaching.’” In re Pers. Restraint of Brown, 143 Wn.2d 431, 453, 21 P.3d 687 (2001)

(quoting State v. Williams, 96 Wn.2d 215, 223, 634 P.2d 868 (1981)). “‘The absence of

any one of the five factors is grounds for the denial of a new’” proceeding. Id.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
State v. Williams
634 P.2d 868 (Washington Supreme Court, 1981)
In Re Brown
21 P.3d 687 (Washington Supreme Court, 2001)
In re the Personal Restraint of Brown
143 Wash. 2d 431 (Washington Supreme Court, 2001)
In re the Personal Restraint of Stenson
76 P.3d 241 (Washington Supreme Court, 2003)

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