LaMone v. Navajo Nation

3 Navajo Rptr. 87
CourtNavajo Nation Court of Appeals
DecidedJune 11, 1982
DocketNo. A-CR-02-81
StatusPublished

This text of 3 Navajo Rptr. 87 (LaMone v. Navajo Nation) is published on Counsel Stack Legal Research, covering Navajo Nation Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LaMone v. Navajo Nation, 3 Navajo Rptr. 87 (navajoctapp 1982).

Opinion

OPINION

This is an appeal from the conviction of Eugene LaMone for the crime of trespass with force. The arrest, trial and conviction of the defendant were aE connected with the occupation of the ConsoEdated Coal Mine site at Burnham, Navajo Nation (New Mexico) during July of 1980.

The events and facts of this case are somewhat confusing due to the state of the record, but the Court wiE attempt to set them forth in a logical fashion before discussing their legal aspects. This appeal was not heard upon the fuE record of the case in the trial court for reasons which wiE be discussed below, and the factual basis for this appeal is founded upon the fües of the matter, such as they are.

The property of the Burnham ConsoEdated Coal Mine was occupied by demonstrators, and the defendant was arrested without warrant by the Navajo PoEce Department. He was then charged with the crimes of criminal entry into the property (Case no. SR-CR-7527-80), criminal damage to property at the site (Case no. SR-CR-7526-80), unauthorized use of a motor vehicle (SR-CR-7765-80), unlawful imprisonment (SR-CR-7766-80) and trespass with force (SR-CR-7767-80). The first three charges were washed out by the motion of the prosecutor withdrawing them. The füe shows the defendant was acquitted of the charge of unlawful imprisonment, so only the charge of trespass with force remained .

There are two verdict forms in the füe. Both have the signature of the jury forman, and one says "guüty," whüe the other says "not guilty." The complaint for the charge of trespass with force has two docket numbers: No. WR-CR-6644-80 and SR-CR-7767-80. (The venue of the case was changed from Window Rock to Shiprock). A [88]*88judgment and mittimus dated December 15, 1980 (No. SR-CR-6644-80) shows the defendant was acquitted by the action of the jury, while another dated February 12, 1981 (No. SR-CR-7767-80) shows a conviction. The record of the case is, to say the least, unclear, with conflicting judgments and jury verdicts which do not identify the charge.

The contentions raised by the defendant in his appeal are: 1) There was an illegal warrantless arrest, 2) the complaint was insufficient because of the lack of knowledge of the complainant; 3) there was insufficient evidence to support the verdict, and 4) a stay of execution should have been granted. Issue 4 is moot and issue 3 will not be reached because of our reversal on other grounds.

THE NEED FOR A WARRANT IN DEMONSTRATION SITUATIONS

The defendant has briefed his case very well, particularly with regard to the law of illegal arrest. The court does not have the benefit of a brief on the part of the prosecution so it will rely upon facts contained in the defendant's brief. (We would have thought the prosecution would be well-prepared to brief a case with such importance as this case has).

The arresting officer did not see the crime of trespass with force committed in his presence and made the arrest upon the statement of another officer who also did not see any illegal events, the defendant's brief states.

Our arrest statute, 7 NTC Sec. 1804, indicates an arrest can be made by a Navajo Police Officer 1) where the offense occurs in the presence of the arresting officer, 2) where the arresting officer has "reasonable evidence that the person arrested has committed an offense," or 3) where the officer has an arrest warrant. Arrest upon the commission of an offense in the presence of the officer is the most obvious, and since the facts to support the main charge merge with the justification for the arrest, that ground for arrest is usually adjudicated at trial and does not become the subject of a pretrial motion. The other ground we are concerned with is an arrest on reasonable evidence the individual has committed an offense. The test for this ground for officers is:

"Whether at the moment the facts and circumstances within their knowledge and of which they had reasonably trustworthy information were sufficient to warrant a prudent man in believing that the petitioner had committed or was committing an offense." Beck v. Ohio, 379 U.S. 89, 91 (1964).

The standard under our statute is not "probable cause" - it is "reasonableness." When the arresting officer makes his arrest, can he satisfy the judge there was enough evidence to believe the individual had committed an offense or was in the act of committing an offense? This judgment is to be made on all the facts the officer had before him and not on the basis of picking out and pooh-poohing an individual element of an offense. See United States v. Pearson, 448 F.2d 1207 (CA 5, 1974).

In this case, although the arresting officer did not see an offen[89]*89se being committed, he could have had sufficient information to have reasonable evidence of a committed offense. While we do not here bar an appellate review of reasonable cause for arrest, normally the trial judge's factual determination of such reasonable cause will not be overturned on appeal. The trial judge here found the arrest was proper and we are not necessarily in a position to overturn that determination. After ah, the defendant was not only arrested for trespass with force at that time but for other offenses as well. There may well have been sufficient evidence to support the arrest for the other charges which were allegedly committed wthin a short time before the arrest.

The appellant's complaint is that since the compound was surrounded by about 75 armed police and it had been secured from about 10:00 a.m. until the time of the defendant's arrest at about 1:30 p.m., there was plenty of time to get a warrant. However that is not the way demonstration and occupation situations work. The police here used fairly standard procedures. They surrounded the compound, arrested individuals who are clearly inside the Consolidated Coal area, and they photographed the defendant with arresting officers to tie him to the unlawful occupation. This is standard procedure, and because of the numbers of defendants present, the difficulty in identification from afar and the nature of the situation, arrest warrants are simply not practical as normal riot procedure. See Standard 7.3, "Organizing for Control," National Advisory Commission on Criminal Justice Standards and Goals - Police (1973); Standard 7.4, "Mass Processing of Arrestees," Id.; Report of the National Advisory Commission on Civil Disorders, pp. 347-348 (Bantam Ed., 1968). (None of these authorities call for arrest with warrant).

WHO MUST SIGN THE COMPLAINT

The defendant complains the individual who signed the complaint had no knowledge of the charges against him and did not appear at trial to testify. That appears to be the case, since a number of witnesses were listed on the complaint and the officer signing the complaint, Doyle Hughes, was not listed with them.

Simply because an individual who signs a complaint and does not appear at trial, that is not necessarily sufficient to challenge the validity of a complaint. The ability of the prosecution to prove its case is a matter entirely independent from the sufficiency of the complaint.

The statute setting forth the complaint form requirements, 17 NTC Sec. 1801, indicates the complaint must be signed by the "complainant" or the "complaining witness." The "complainant" is clearly the victim of the alleged offense, e.g.

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