State Of Washington, V. Emanuel Kozma

CourtCourt of Appeals of Washington
DecidedMay 18, 2026
Docket86833-1
StatusUnpublished

This text of State Of Washington, V. Emanuel Kozma (State Of Washington, V. Emanuel Kozma) 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. Emanuel Kozma, (Wash. Ct. App. 2026).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 86833-1-I Respondent,

v. DIVISION ONE

EMANUEL KOZMA, UNPUBLISHED OPINION Appellant.

CHUNG, J. — Emanuel Kozma was convicted of assault in the first degree while

armed with a firearm and unlawful possession of a firearm in the second degree. He

challenges his convictions on several grounds. First, he argues that he was denied his

right to present a defense and his right to confront witnesses when he was prevented

from asking a witness about his knowledge of the victim’s allegedly abusive relationship.

He further contends that the trial court violated these rights when it prevented him from

recalling this witness to impeach the victim’s testimony. He then argues that he received

ineffective assistance when his counsel failed to argue that the witness’s testimony was

admissible and that it was necessary to recall the witness to present evidence of

another suspect. He also raises additional issues in a statement of additional grounds

for review (SAG). We conclude the trial court did not err and that Kozma does not

satisfy his burden to show ineffective assistance of counsel. Therefore, we affirm. No. 86833-1-I/2

BACKGROUND

Emanuel Kozma and Amanda James met sometime between 2016 and 2017,

when Kozma dated James’s sister. Kozma and James continued to be in contact, as

Kozma was a friend of James’s brother. Sometime in August 2022, Kozma drove James

to the house of his friend, Thomas Hobart, so she could see his dog, which she knew

from its previous owner. James had not previously met Hobart, but the two got along.

After Kozma left that evening, James remained at the house, and James testified that

Kozma took her phone when he left, leaving her with only her “backup phone,” which

worked only when connected to a Wi-Fi network.

A few days after Hobart and James first met, on August 15, 2022, the two were

painting Hobart’s RV when Kozma came over with a scooter for Hobart to work on.

James testified that while Kozma was in the garage, she confronted him and demanded

to know where her phone was located. She said that as the two argued about the

phone, Kozma took a gun out of his backpack and put it to James’s forehead, telling her

to shut up “or I’m going to shoot you.” According to James, she then pushed the gun

away from her, turned around, and began to walk away. She walked, at most, a foot or

two before she was shot in the back of the neck. James testified that Hobart was in the

garage for the whole argument, including when she was shot.

According to Hobart, when James and Kozma began arguing, he left the garage

to get parts from a nearby shed. Hobart testified that he was at the shed for a “couple

minutes” and could hear James and Kozma arguing. He then heard a gunshot or “bang,

a little pop sound” that he thought was a firecracker, and the arguing stopped. He

clarified that he did not hear anyone other than Kozma and James arguing in the

2 No. 86833-1-I/3

garage. Hobart walked back to the garage and, as he was approaching, it sounded like

a truck “was stopped and it took off from a dead stop,” although he never saw the

vehicle. He also thought he heard someone say something like “Let’s go,” but he was

not certain. Hobart testified that he did not see anyone other than James and Kozma at

his home at that time.

Hobart said after hearing the shot, he returned to the garage within

approximately 15 seconds. He saw James on the floor and Kozma nearby, and he

asked Kozma to “get [James] up.” Kozma “got [James] to wake up,” and told Hobart to

call an ambulance. Hobart retrieved his phone from his truck, which was about 10 feet

away from the garage. Kozma left as Hobart called 911.

While on the phone with the 911 operator, James identified the shooter several

times as “Emanuel,” Kozma’s first name. Hobart provided a physical description of

Kozma because he was “the only person [Hobart] saw with [James] prior to the

shooting.” When King County Sheriff’s Office Detectives Daniel McCreary and Jean

Marquez Romero arrived on the scene, McCreary asked James who had shot her, and

she told him “Emanuel.”

James was taken by ambulance to Harborview Hospital, where doctors

discovered her injuries included a bullet fragment in her cervical spine and a broken

vertebra. In the days after the shooting, both Hobart and James were shown six-person

photo montages and identified Kozma as the perpetrator. James remained in the ICU

for months following the shooting. By the time of trial in 2024, James had recovered

some movement in her arms, but she still had no movement in her hands or legs.

3 No. 86833-1-I/4

The State charged Kozma with three counts: (1) assault in the first degree with a

firearm enhancement, (2) assault in the second degree with a firearm enhancement and

the aggravator of injuries substantially exceeding the level of bodily harm necessary to

satisfy the elements of assault in the second degree, and (3) unlawful possession of a

firearm in the second degree. The parties agreed to bifurcate the proceedings for the

unlawful possession of a firearm charge.

The jury convicted Kozma as charged on the two assault charges. It then heard

evidence on the unlawful possession charge and found Kozma guilty on that count, as

well. At sentencing, the trial court granted an agreed order vacating count two for

assault in the second degree because it merged with count one for assault in the first

degree. The trial court sentenced Kozma to a standard-range sentence of 279 months,

as well as a 60-month firearm enhancement, for a total of 339 months. Kozma filed a

timely notice of appeal.

DISCUSSION

Kozma contends that the trial court erred and denied him his right to present a

defense and his right to confront witnesses when it prevented him from asking Hobart

about his knowledge of an allegedly abusive relationship James was in at the time of

the shooting. He also argues that the court erred by denying his request to recall Hobart

as a witness to impeach James’s testimony that she was not in an abusive relationship.

Additionally, he contends that he received ineffective assistance when his counsel failed

to argue that Hobart’s testimony and recall were admissible because they were “other

suspect” evidence. Finally, he asserts that cumulative error denied him a fair trial.

4 No. 86833-1-I/5

I. Right To Present a Defense

Kozma’s claims relating to his right to present a defense and right to confront

witnesses are based on his attempts to elicit testimony from Hobart about James’s

allegedly abusive relationship. The court limited this line of questioning, concluding first,

that it was hearsay and later, that to the extent Hobart’s testimony would impeach

James, it would be about a collateral matter.

Before trial, the State filed a motion in limine to “preclude other suspect

evidence.” In response, Kozma clarified that his defense was general denial, and he

had not provided notice of an “other suspect” defense and “that’s not [his] intent here.”

However, he wanted to ensure that this ruling did not preclude him from “arguing to the

jury that they should have doubt about who committed this . . . there’s no physical

evidence tying [Kozma] to this. So[,] it kind of implies, without naming an actual other

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