State of Missouri v. Rhamir Jaheim Washington

CourtMissouri Court of Appeals
DecidedMay 21, 2024
DocketWD86417
StatusPublished

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

Bluebook
State of Missouri v. Rhamir Jaheim Washington, (Mo. Ct. App. 2024).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT STATE OF MISSOURI, ) ) Respondent, ) ) v. ) WD86417 ) RHAMIR JAHEIM WASHINGTON, ) Opinion filed: May 21, 2024 ) Appellant. )

APPEAL FROM THE CIRCUIT COURT OF BOONE COUNTY, MISSOURI THE HONORABLE JOSHUA C. DEVINE, JUDGE

Division Three: Mark D. Pfeiffer, Presiding Judge, Lisa White Hardwick, Judge and W. Douglas Thomson, Judge

Rhamir Jaheim Washington (“Washington”) appeals a judgment entered by

the Circuit Court of Boone County (“trial court”) in which he was found guilty of

third-degree domestic assault and received a three-year sentence. Washington

raises four points on appeal. In Points I and II, Washington claims that the trial

court erred in overruling his objection to the State’s filing of a second substitute

information which added the allegations that Washington was a persistent assault

offender and a persistent misdemeanor offender because during the cases which

support the repeat offender charges he was without representation at “critical stages.” In Point III, Washington contends the trial court erred in overruling his

submitted jury instructions which were applicable to jury punishment because he

was eligible for jury punishment in the event of a guilty verdict. In Point IV,

Washington argues the trial court erred in denying his motion to dismiss for

improper preliminary hearing because the trial court lacked jurisdiction to hear

the case because the “complainant” was not examined at the preliminary hearing.

Finding no error, we affirm.

Factual and Procedural History

The State initially charged Washington with the class D felony of second-

degree domestic assault by felony complaint, alleging Washington recklessly

caused serious physical injury to Victim, a woman with whom he had a child in

common, by striking her repeatedly in the face on or about May 22, 2022. Attached

to the complaint filed in the associate division of the circuit court was a probable

cause statement prepared and signed by the responding police officer. Following

a preliminary hearing which found there was probable cause to believe

Washington had committed a felony, an information was filed charging

Washington with the class D felony of domestic assault in the second degree.

Victim was the sole witness for the State at the preliminary hearing. Thereafter,

Washington filed a motion to dismiss for improper preliminary hearing, alleging

the responding police officer, who authored the initial probable cause statement,

was the “complainant.” He further alleged that because the “complainant” had not

testified at the preliminary hearing as required under section 544.270, RSMo 1939,

2 he was denied his right to a preliminary hearing under section 544.250, RSMo 1979

and the trial court was without jurisdiction to hear the case.1 The motion was taken

under advisement and later denied.

The State subsequently moved for leave to file a substitute information,

which alleged Washington to be a persistent assault offender under section

565.079 on the basis of two prior convictions of domestic assault in the fourth

degree in 2021 and 2022. Washington opposed the motion, arguing the State

should not be permitted to use these prior convictions to enhance his sentence as

he was denied counsel at critical stages in the course of both. Washington claimed

these critical stages were the review of his bond conditions at the initial appearance

in the 2021 case, and the decision on whether to exercise his right to a change of

judge in the 2022 case. Arguments were heard on the motion at pretrial conference

and the trial court later granted the State’s motion to file the substitute

information, which was then filed.

Jury trial commenced on May 17, 2023. Prior to the start of trial, a hearing

was held on Washington’s offender status. The State requested the trial court to

take judicial notice of the findings of guilt of fourth-degree domestic assault in both

the 2021 and 2022 cases, and based on those findings, to find that Washington is

a prior and persistent assault offender. The State also argued that the trial court

could find Washington is a persistent misdemeanor offender under section

1 Other than these two statutes, all statutory citations are to RSMo (2017).

3 558.016, in addition to a persistent assault offender, based on the same two prior

convictions.

A brief recess took place to allow the State to prepare a second substitute

information to include language concerning the persistent misdemeanor offender

allegation. Once back on the record, the trial court acknowledged the objections

Washington had lodged against the initial substitute information, and allowed

Washington to make additional objections to the second substitute information at

that time. The trial court overruled Washington’s objections, and the second

substitute information was filed. Upon recommencing the offender status hearing,

Washington reasserted his objection to the State’s use of the two prior convictions

on the ground that he was denied counsel at critical stages in both cases. The trial

court ultimately denied Washington’s objection, and based on the evidence

adduced, found that Washington was both a persistent assault offender under

section 565.079 and a persistent misdemeanor offender under section 558.016.

Following the close of evidence at trial, an instruction conference was held,

during which Washington offered instructions related to jury sentencing. The trial

court denied the request to submit said instructions, having already found that

Washington was ineligible for jury sentencing due to his status as a persistent

assault offender and a persistent misdemeanor offender. The jury returned a

verdict finding Washington guilty of the lesser-included offense of domestic

assault in the third degree, a class E felony. On July 14, 2023, the trial court

sentenced Washington to a three-year term of imprisonment.

4 Washington appeals.

Point I and Point II2

In Points I and II, Washington claims the trial court erred in overruling his

objection to the State’s filing of the second substitute information in which he was

alleged to be a persistent assault offender and a persistent misdemeanor offender,

respectively, and in finding the State adduced sufficient evidence on those offender

statuses. In both points Washington contends these trial court errors stem from

the use of his 2021 and 2022 convictions in proving those respective offender

statuses. In particular, Washington argues that he was deprived of counsel at

“critical stages” in each of his previous findings of guilt, specifically the “bail or

bond review hearing” in his 2021 case and “the decision whether to exercise the

right to change of judge under Rule 32.06” in the 2022 case. Washington claims

that at the offender status hearing, the State failed to prove that he was either

represented by counsel or waived counsel at such critical stages during the 2021

2 Our review of Washington’s Points I and II is made difficult by Washington’s

briefing to this court, which has failed to comply with the requirements of Rule 84.04(c) in that his Statement of Facts only generally references the hearings where Washington claims he was unconstitutionally without counsel. “‘Failure to meet the requirements set forth in Rule 84.04(c) is grounds for dismissal.’” Brown v. Brown, 645 S.W.3d 75, 83 (Mo.

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State of Missouri v. Rhamir Jaheim Washington, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-missouri-v-rhamir-jaheim-washington-moctapp-2024.