People v. Joseph Wayne Washington

CourtColorado Court of Appeals
DecidedJune 9, 2022
Docket19CA1332
StatusPublished

This text of People v. Joseph Wayne Washington (People v. Joseph Wayne Washington) is published on Counsel Stack Legal Research, covering Colorado Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Joseph Wayne Washington, (Colo. Ct. App. 2022).

Opinion

The summaries of the Colorado Court of Appeals published opinions constitute no part of the opinion of the division but have been prepared by the division for the convenience of the reader. The summaries may not be cited or relied upon as they are not the official language of the division. Any discrepancy between the language in the summary and in the opinion should be resolved in favor of the language in the opinion.

SUMMARY June 9, 2022

2022COA62

No. 19CA1332, People v. Washington — Criminal Procedure — Permissive Joinder — Misjoinder; Appeals — Standard of Review — Harmless Error

A division of the court of appeals holds as a matter of first

impression that People v. Novotny, 2014 CO 18, overruled Norman

v. People, 178 Colo. 190, 496 P.2d 1029 (1972), to the extent

Norman held that joinder error was automatically reversible.

Instead, the division holds that misjoinder under Crim. P. 8(a)(2) is

subject to harmless error review. COLORADO COURT OF APPEALS 2022COA62

Court of Appeals No. 19CA1332 Arapahoe County District Court No. 17CR2285 Honorable Patricia D. Herron, Judge

The People of the State of Colorado,

Plaintiff-Appellee,

v.

Joseph Wayne Washington,

Defendant-Appellant.

JUDGMENT AFFIRMED

Division I Opinion by JUDGE BERGER Dailey and Tow, JJ., concur

Announced June 9, 2022

Philip J. Weiser, Attorney General, William G. Kozeliski, Senior Assistant Attorney General, Denver, Colorado, for Plaintiff-Appellee

Megan A. Ring, Colorado State Public Defender, Meredith E. O’Harris, Deputy State Public Defender, Denver, Colorado, for Defendant-Appellant ¶1 Defendant, Joseph Wayne Washington, appeals his

convictions for second degree murder, ten counts of possession with

intent to sell or distribute a controlled substance, tampering with a

witness or victim, and violation of a protection order.

¶2 His only contention on appeal is that the trial court erred by

trying the murder charge and the drug charges together.

¶3 We hold as a matter of first impression that People v. Novotny,

2014 CO 18, overruled Norman v. People, 178 Colo. 190, 496 P.2d

1029 (1972), to the extent Norman held joinder error requires

automatic reversal. Instead, we hold that misjoinder under Crim. P.

8(a)(2) is subject to harmless error review.

¶4 Reviewing for harmless error, we conclude that any joinder

error was harmless, and we affirm.

I. Relevant Facts and Procedural History

¶5 Evidence presented at trial allowed the jury to find the

following facts. Washington and his girlfriend attended a barbeque

at Cherry Creek State Park hosted by Jason Pope. Jackson Chavez

and his ex-girlfriend, who were at the park with a different group,

started to argue, and the fight turned physical. Chavez’s behavior

made two of Pope’s friends uncomfortable and upset, so they told

1 Pope and Washington about Chavez’s behavior. Pope’s friends also

told Pope that he should ask Chavez to leave. Pope and

Washington approached Chavez and asked him to leave.

¶6 Chavez threw a punch that “hit [Washington] and then clipped

[Pope].” Pope swung at Chavez and Chavez’s return punch

“knocked out” Pope. Washington “turned around, walked maybe 20

feet away, . . . got a gun, and . . . turned around and shot [Chavez]”

twice in the chest, killing him. The gun was located in a brown

backpack that Washington and his girlfriend brought with them to

the barbeque. After killing Chavez, Washington left the park with

his girlfriend.

¶7 Washington and his girlfriend returned to his house in Aurora,

where they packed two backpacks, including the brown backpack

they had at the barbeque. Washington’s roommate testified at trial

that he purchased drugs from Washington in the past and that he

arranged for an Uber to take Washington and his girlfriend to

downtown Denver.

¶8 Washington and his girlfriend went to Richard Giles’

downtown apartment. Giles booked Washington and Washington’s

girlfriend a hotel room for the night. Washington gave Giles “like a

2 gram of cocaine or something and then they left.” At trial, Giles

testified that he previously purchased drugs from Washington.

¶9 The next morning, Raymond Wallace, another of Washington’s

friends, picked up Washington and Washington’s girlfriend from the

hotel and they went to a restaurant. After eating and having a few

drinks, they drove to a gas station, where Washington was arrested

for Chavez’s murder.

¶ 10 The police obtained a search warrant for the vehicle in which

Washington was seated when he was arrested. The police found

two backpacks (including the brown backpack) in the backseat of

the vehicle. When they searched the backpacks, the police found

various drugs and drug paraphernalia. The police also obtained a

search warrant for Washington’s house, where they found more

drugs and drug paraphernalia.

¶ 11 The prosecution charged Washington with first degree murder.

The court issued a mandatory protection order prohibiting

Washington from contacting or directly or indirectly communicating

with his girlfriend. The prosecution later amended the complaint to

include eleven counts of possession with intent to sell or distribute

a controlled substance.

3 ¶ 12 While in jail awaiting trial, Washington wrote a letter to his

girlfriend and called her, discussing her communications with the

police, his charges, and possible defenses. As a result of the letter

and the jail calls, the prosecution charged Washington with

violation of a protection order and tampering with a witness or

victim.

¶ 13 Separately, Shamarr Long-Frazier, who was housed at the jail

with Washington, told the prosecution that Washington told two

other men at the jail that “he needed to get rid of [his girlfriend].”

The prosecution further amended the complaint to include two

counts of solicitation to commit murder in the first degree.

¶ 14 Before trial, Washington moved to sever, arguing both

improper joinder under Crim. P. 8 and that he was entitled to relief

from prejudicial joinder under Crim. P. 14.

¶ 15 The trial court ruled that joinder under Crim. P. 8(a)(2) was

permissible because the charges were “all interrelated and

interconnected in a number of ways.” The trial court also denied

Washington’s discretionary request for severance under Crim. P. 14.

¶ 16 At trial, although Washington did not testify, his counsel

argued that Washington shot Chavez in self-defense and defense of

4 others. Also through counsel, Washington claimed that the drugs

did not belong to him. Washington’s counsel admitted that

Washington violated a protection order.

¶ 17 The jury convicted Washington of second degree murder, ten

counts of possession with intent to sell or distribute a controlled

substance, violation of a protection order, and tampering with a

witness or victim. The jury acquitted Washington of first degree

murder,1 one count of possession with intent to sell or distribute a

controlled substance, and the two solicitation to commit murder

charges.

II. Even if the Trial Court Erroneously Joined Washington’s Charges Under Crim. P. 8(a)(2), Any Error was Harmless

¶ 18 Washington first argues that the trial court reversibly erred by

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People v. Joseph Wayne Washington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-joseph-wayne-washington-coloctapp-2022.