State Of Washington v. Aaron Joseph Owens

CourtCourt of Appeals of Washington
DecidedMarch 30, 2021
Docket53925-0
StatusUnpublished

This text of State Of Washington v. Aaron Joseph Owens (State Of Washington v. Aaron Joseph Owens) 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
State Of Washington v. Aaron Joseph Owens, (Wash. Ct. App. 2021).

Opinion

Filed Washington State Court of Appeals Division Two

March 30, 2021 IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 53925-0-II

Respondent,

v.

AARON JOSEPH OWENS, UNPUBLISHED OPINION

Appellant.

GLASGOW, J.—Aaron Joseph Owens is required to register as a sex offender with the local

sheriff’s office, and he registered that he was living at his father’s address. Sergeant Cameron

Simper visited Owens’s father’s address, and Owens’s father told Simper that his son was not

living there. The State charged Owens with failure to register as a sex offender.

Owens proceeded to a bench trial where Simper repeated Owens’s father’s statement that

Owens was not living with him. The State referred to this statement several times in closing

argument, and defense counsel did not object or seek to limit consideration of this statement during

the trial. In a posttrial motion for arrest of judgment, Owens argued that the trial court improperly

considered this hearsay testimony as substantive evidence of Owens’s guilt, rather than for the

limited purpose of impeaching Owens’s father’s trial testimony. Owens argued that without this

statement, the State failed to prove that Owens was not living at his registered address. The trial

court rejected both arguments.

On appeal, both parties agree that the statement was hearsay, and the State does not dispute

that the trial court considered the statement as substantive evidence. Instead, the State argues that No. 53925-0-II

Owens waived the issue by failing to object during trial. We hold that the trial court improperly

relied on Simper’s hearsay testimony as substantive evidence, but we need not reach the issue of

waiver because, viewing the evidence in the light most favorable to the State, the evidence was

sufficient to sustain Owens’s conviction without the hearsay testimony. We affirm.

FACTS

Owens is required to register as a sex offender. In May 2018, he updated his address with

the Thurston County Sheriff’s Office and registered at his father’s address. On June 21, 2018,

Simper went to this address to verify that Owens was living there. Owens’s father, Thomas

Owens,1 answered the door and told Simper that “he hadn’t seen [Owens] in months and that

[Owens] didn’t live at the house.” Clerk’s Papers (CP) at 2. Simper was unable to contact Owens,

and a warrant was issued for his arrest. The State charged Owens with failure to register as a sex

offender in violation of RCW 9A.44.132(1)(a).

A. Trial

Owens waived his right to a jury trial and proceeded to a bench trial. Owens did not contest

that he was required to register as a sex offender or that he was registered at his father’s address

during the relevant time period. The only dispute at trial was whether Owens was actually living

at his registered address. His defense was that “statements law enforcement attributed to Thomas

Owens were either misunderstood or misrepresented.” CP at 10.

Thomas testified at trial. At first, Thomas recalled Simper coming to his home in summer

2018 and asking, “[W]as Aaron Joseph there?” Verbatim Report of Proceedings (VRP) (June 18,

1 Because Thomas Owens shares a last name with Aaron Owens, we refer to Aaron Owens as “Owens,” and we use Thomas’s first name.

2 No. 53925-0-II

2019) at 12. Thomas testified that he responded, “‘Not at this time.’” Id.; see also id. at 13-14

(repeating this testimony two more times). Thomas denied telling law enforcement that Owens

was not living at the house.

On cross-examination, however, Thomas became confused about when the encounter with

Simper occurred and gave conflicting testimony about whether Owens lived at his home when

Simper visited. Thomas insisted, “Nobody came to my house a year ago, that I can remember.” Id.

at 22. Thomas testified that during summer 2018, his son was “in and out of the house.” Id. at 21.

He said that Owens had a room at his house, that Owens received mail there, and that Owens’s

children lived there. But at the end of his testimony, Thomas said that “when [Owens] wasn’t

living with [Thomas], he had his own place, and that was right across the street.” Id. at 22. On

redirect, Thomas said that “as far as telling you when [Owens] was there and when he wasn’t, I

couldn’t, not a year ago.” Id. at 23. Then he stated that Owens was living across the street from

him “[t]he whole time,” meaning “[o]ver a year.” Id. However, he also stated that Owens was

living with him in June and July 2018.

Simper testified about going to the address where Owens was registered and speaking with

Thomas. Simper testified that he did not see Owens at the residence and that Thomas “said that

Aaron Owens was his son and that he did not live there.” Id. at 32. On cross-examination, Simper

confirmed that he was not taking notes, recording, or wearing a body camera during this encounter.

But in response to a question of whether it was “possible [Thomas] said he hadn’t seen [Owens],”

Simper said, “No, I recall him saying [Owens] didn’t live there.” Id. at 35-36 (emphasis added).

Owens also testified. He recalled that during summer 2018, due to his and his father’s work

schedules, the two did not see one another very often. In addition, Owens sometimes needed to

3 No. 53925-0-II

travel for work and he spent nights in hotels. Sometimes he spent all night working, and sometimes

he slept in his car. But Owens testified that he moved into his father’s house in May 2018 and that

he was living there in June and July 2018. He also stated that his father had been experiencing

difficulty with his memory.

In closing argument, the State argued that it had shown Owens was not living at the address

where he was registered. In support of this argument, the State referred to Thomas’s testimony that

Owens lived across the street and reminded the court that “when the police officer came to his

house, [Thomas] said he hadn’t seen [Owens] in [a while].” Id. at 87. The State argued it was

“unlikely” that Owens and his four children would have been living in Thomas’s house “and yet

[Thomas] would have no recollection of having seen [Owens].” Id. at 87-88. The State repeated,

“Thomas Owens said his son lived across the street and that he hadn’t seen his son in a while when

the police came on June 21st and asked him.” Id. at 88. It concluded, “[W]hen the defendant’s

father on June 21st, 2018 said he hadn’t seen the defendant and the defendant didn’t live there, it

meant that, that the defendant didn’t live there.” Id. at 89. Defense counsel did not object.

In defense counsel’s closing argument, she referenced the “statement made by Mr. Thomas

Owens, my client’s father, that he hadn’t seen [Owens] in months,” and she noted that “[t]his

would have been through the impeachment testimony of Sergeant Simper.” Id. (emphasis added).

But then defense counsel argued that Simper’s recollection of Thomas’s statement could have been

faulty and that this statement alone was not enough to convict beyond a reasonable doubt because

it was not corroborated. Counsel argued, “One person’s statement, even if we take it at face value,

should not be proof beyond a reasonable doubt.” Id. at 91. She did not expressly argue that

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