State of Washington v. Cameron J. Peterson

CourtCourt of Appeals of Washington
DecidedDecember 18, 2018
Docket35686-8
StatusUnpublished

This text of State of Washington v. Cameron J. Peterson (State of Washington v. Cameron J. Peterson) 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. Cameron J. Peterson, (Wash. Ct. App. 2018).

Opinion

FILED DECEMBER 18, 2018 In the Office of the Clerk of Court WA State Court of Appeals, Division III

STATE OF WASHINGTON, ) ) No. 35686-8-III (consolidated Respondent, ) with No. 35853-4-III) ) v. ) ) CAMERON J. PETERSON, ) ) UNPUBLISHED OPINION Appellant. ) __________________________________ ) UN)) IN THE MATTER OF PERSONAL ) RESTRAINT OF ) ) CAMERON J. PETERSON ) Resondent,

FEARING, J. — Cameron Peterson appeals a superior court order denying his

motion to issue a postconviction subpoena duces tecum for medical records. In a

consolidated personal restraint petition, Peterson seeks the same relief. We affirm the

superior court’s denial of relief.

FACTS

On April 12, 2015, Cameron Peterson and Gregory Zielke Sr. patronized a tavern.

Someone forcefully struck Zielke on his head, and the blow rendered Zielke unconscious.

At trial, the State presented witnesses who testified that Peterson walloped Zielke with a No. 35686-8-III cons. w/35853-4-III State v. Peterson; Personal Restraint of Peterson

bottle, glass, or other object. One witness described a resulting “‘gash’” on Zielke’s

head that caused significant bleeding. Clerk’s Papers at 37. Peterson has always denied

striking the blow. Following the assault, medical personnel transported Gregory Zielke

to Sacred Heart Medical Center.

The State charged Cameron Peterson with second degree assault. The prosecution

did not introduce at trial medical records for the hospital treatment of Zielke. A jury

convicted Peterson of the charge. The superior court sentenced Peterson to three months’

confinement.

Cameron Peterson appealed his conviction. This court held that sufficient

evidence supported the conviction and affirmed the conviction.

PROCEDURE

Following the appeal of the conviction for second degree assault, Cameron

Peterson, citing CrR 4.8(b), filed a motion in the superior court for issuance of a

subpoena duces tecum directing the records custodian for Sacred Heart Medical Center to

produce all records relating to the diagnosis and treatment of Gregory Zielke for the head

injury. In support of the subpoena request, Peterson argued that he did not assault Zielke

as described by witnesses and the medical records would confirm a lack of injury to

Zielke’s head.

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The superior court denied the motion for issuance of the subpoena duces tecum.

The court ruled that CrR 4.8 applied only to pretrial discovery. Peterson appealed this

decision to this court.

Cameron Peterson later filed with the superior court a motion, under CrR

7.8(b)(2), (3) and (5), for relief from judgment and for discovery. Pursuant to CrR

7.8(c)(2), the superior court transferred the motion to this court as a personal restraint

petition. This court consolidated the appeal with the personal restraint petition.

LAW AND ANALYSIS

Despite consolidating Cameron Peterson’s personal restraint petition with his

appeal, we separate the two for purposes of analysis. Although Peterson seeks a

subpoena duces tecum for medical records in each proceeding, the rules attending the

request differ within the two proceedings. We also address his request within the context

of a motion to vacate judgment under CrR 7.8.

Appeal

After completion of the appeal of his conviction, Cameron Peterson asked the

superior court to issue a subpoena duces tecum, under CrR 4.8(c), to obtain the medical

records of his victim. The superior court ruled that CrR 4.8 applies only to pretrial

motions. We agree.

Cameron Peterson seeks to garner a subpoena duces tecum for discovery purposes.

CrR 4.7 governs criminal discovery. State v. Pawlyk, 115 Wn.2d 457, 471, 800 P.2d 338

3 No. 35686-8-III cons. w/35853-4-III State v. Peterson; Personal Restraint of Peterson

(1990). CrR 4.8 addresses subpoenas. The title to section 4 of the criminal rules for

Superior Court, which contains CrR 4.7 and 4.8, is “PROCEDURES PRIOR TO TRIAL”

CrR 4.7, which addresses discovery, speaks in terms of discovery leading to trial. The

discovery rules constitute pretrial mechanisms to facilitate litigation and preserve a

defendant’s rights while preparing for trial. See State v. Copeland, 89 Wn. App. 492,

497, 949 P.2d 458 (1998).

CrR 4.8(a)(1)(B) refers to “[t]he court in which the action is pending” as the body

issuing the subpoena. After the appeal affirms the conviction, no action pends before the

superior court.

In District Attorney’s Office for the Third Judicial District v. Osborne, 557 U.S.

52, 129 S. Ct. 2308, 174 L. Ed. 2d 38 (2009), the United States Supreme Court suggested

that a defendant may not engage in ongoing disclosure after a conviction. After a

conviction, the defendant has been “constitutionally deprived” of his liberty, the

presumption of innocence is gone, and a defendant is no longer entitled to the same

pretrial liberty interests. District Attorney’s Office for the Third Judicial District v.

Osborne, 557 U.S. at 68-69. Our own state Supreme Court shares the same view as the

Court in Osborne. See generally State v. Mullen, 171 Wn.2d 881, 902, 259 P.3d 158

(2011) the Washington Supreme Court observed that pretrial discovery principles do not

apply to postconviction processes.

An offender may possess a due process right for postconviction discovery. In re

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Personal Restraint of Gentry, 137 Wn.2d 378, 972 P.2d 1250 (1999). In Gentry, the

court noted that, although a defendant possesses no due process right to discovery as a

matter of course postconviction, the defendant may obtain discovery to the extent he or

she can show good cause to believe discovery would prove entitlement to other relief. In

re Personal Restraint of Gentry, 137 Wn.2d at 390-91. In his brief, Cameron Peterson

cited Gentry, but he employs the decision in his CrR 4.8 argument. He does not assert

the due process clause.

Motion to Vacate Judgment

We question whether we should address Cameron Peterson’s motion to vacate his

conviction under CrR 7.8 when the motion becomes a personal restraint petition when

transferred to this appeal court. We analyze Peterson’s claim under CrR 7.8 anyway.

Cameron Peterson argues that, by filing a motion to vacate his conviction under

CrR 7.8, a new action is now “pending” before the trial court and therefore he gains

entitlement to use the criminal discovery rules to obtain the subpoena duces tecum. The

argument contains some logic, but falls short when considering the limited nature of CrR

7.8.

CrR 7.8(b) declares:

On motion and upon such terms as are just, the court may relieve a party from a final judgment, order, or proceeding for the following reasons: (1) Mistakes, inadvertence, surprise, excusable neglect or irregularity in obtaining a judgment or order;

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Related

In Re the Personal Restraint of Hews
660 P.2d 263 (Washington Supreme Court, 1983)
State v. Copeland
949 P.2d 458 (Court of Appeals of Washington, 1998)
In Re Personal Restraint of Gentry
972 P.2d 1250 (Washington Supreme Court, 1999)
Matter of Personal Restraint of Grisby
853 P.2d 901 (Washington Supreme Court, 1993)
In Re the Personal Restraint of Cook
792 P.2d 506 (Washington Supreme Court, 1990)
State v. Williams
634 P.2d 868 (Washington Supreme Court, 1981)
State v. Mullen
259 P.3d 158 (Washington Supreme Court, 2011)
State v. Pawlyk
800 P.2d 338 (Washington Supreme Court, 1990)
State v. Sutherby
204 P.3d 916 (Washington Supreme Court, 2009)
In re the Personal Restraint Gentry
972 P.2d 1250 (Washington Supreme Court, 1999)
State v. Sutherby
165 Wash. 2d 870 (Washington Supreme Court, 2009)
State v. Gassman
160 Wash. App. 600 (Court of Appeals of Washington, 2011)
State v. Cervantes
282 P.3d 98 (Court of Appeals of Washington, 2012)

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