State of Washington v. Eulogio Castro Romero

CourtCourt of Appeals of Washington
DecidedMarch 13, 2014
Docket31224-1
StatusUnpublished

This text of State of Washington v. Eulogio Castro Romero (State of Washington v. Eulogio Castro Romero) 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. Eulogio Castro Romero, (Wash. Ct. App. 2014).

Opinion

FILED

MARCH 13, 2014

In the Office of the Clerk of Court

WA State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION THREE

STATE OF WASHINGTON, ) No. 31224-1-111 ) Respondent, ) ) v. )

I ) EULOGIO CASTRO ROMERO, ) UNPUBLISHED OPINION ) Appellant. )

J Brown, J.-Eulogio Castro Romero appeals his convictions for possessing I methamphetamine and possessing a firearm without an alien firearm license. He I contends the trial court erred in admitting his custodial interrogation statements to a

federal immigration agent and insufficient evidence supports his conviction for

possessing a firearm without an alien firearm license. We affirm.

FACTS

Law enforcement executed a search warrant at Mr. Romero's residence on July

15,2012 around 10:30 p.m. Moses Lake Police Officer Raymond Bernard read Mr.

Romero his Miranda1 rights from a department issued card. Mr. Romero responded that

he understood and gave statements. The search results partly included

methamphetamine on Mr. Romero's bedside table and a firearm under his mattress.

1 Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966). No. 31224-1-111 State v. Romero

The next day, around 10 to 18 hours later, United States Immigration and Customs

Enforcement Agent Jaime Waite took additional statements from Mr. Romero while he

was in jail without giving fresh Miranda warnings. The trial court admitted these

statements at trial after denying Mr. Romero's CrR 3.5 motion to suppress them. A jury

found him guilty as charged of possessing methamphetamine and possessing a firearm

without an alien firearm license. He appealed.

ANALYSIS

A. Miranda Warnings

The issue is whether the trial court erred in admitting Mr. Romero's custodial

interrogation statements to Agent Waite. Mr. Romero solely contends his statements

are inadmissible because Agent Waite obtained them without giving fresh Miranda

warnings. We review the adequacy of Miranda warnings de novo. State v. Campos-

Cerna, 154 Wn. App. 702, 708, 226 P.3d 185 (2010). We review CrR 3.5 factual

findings for substantial evidence. State v. Broadaway, 133 Wn.2d 118, 131,942 P.2d

363 (1997). Substantial evidence supports a factual finding if "a sufficient quantity of

evidence [exists] in the record to persuade a fair-minded, rational person of the truth of

the finding." State v. Hill, 123 Wn.2d 641,644,870 P.2d 313 (1994).

Generally, in addition to due process protections against use of coerced

statements, the State may not admit as trial evidence any statements a suspect makes

during custodial interrogation unless it proves, by a preponderance of evidence, the

suspect received fully effective Miranda warnings and knowingly, intelligently, and

No. 31224-1-111 State v. Romero

voluntarily waived his or her Miranda rights before making the statements. 2 Miranda v.

Arizona, 384 U.S. 436, 478-79,86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966); Colorado v.

Connelly, 479 U.S. 157, 168, 107 S. Ct. 515, 93 L. Ed. 2d 473 (1986). Mr. Romero

does not invoke due process protections here. The State does not dispute that his

conversation with Agent Waite constituted custodial interrogation. 3

"[C]ourts have generally rejected a per se rule as to when a suspect must be

readvised of his rights after the passage of time or a change in questioners." United

States v. Andaverde, 64 F.3d 1305, 1312 (1995) (citing Wyrick v. Fields, 459 U.S. 42,

49,103 S. Ct. 394, 74 L. Ed. 2d 214 (1982». Instead, courts evaluate the totality of the

circumstances in determining whether law enforcement needed to give the suspect

fresh Miranda warnings. See, e.g., United States v. Rodriguez-Preciado, 399 F .3d

1118, 1128-30 (9th. Cir. 2005) (holding Miranda warnings were still effective after 16

hours); Guam v. Dela Pena, 72 F.3d 767,769-70 (9th Cir. 1995) (holding Miranda

warnings were still effective after 15 hours); Puplampu v. United States, 422 F.2d 870,

870 (9th Cir. 1970) (holding Miranda warnings were still effective after two days);

Maguire v. United States, 396 F.2d 327,331 (9th Cir. 1968) (holding Miranda warnings

2 At a minimum, Miranda warnings must inform a suspect "that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him." 384 U.S. at 479. 3 A suspect is in custody when law enforcement formally arrests the suspect or similarly restrains his or her freedom so that a reasonable person under the circumstances would not feel free to terminate the encounter and leave. Thompson v. Keohane, 516 U.S. 99,112, 116 S. Ct. 457,133 L. Ed. 2d 383 (1995). A suspect is subject to interrogation when law enforcement expressly questions the suspect or initiates some functional equivalent, including words or conduct that law enforcement

were still effective after three days); State v. Blanchey, 75 Wn.2d 926, 931, 454 P.2d

841 (1969) (holding Miranda warnings were still effective after four days).

Considering these judicial opinions, we conclude the original Miranda warnings

were still effective 10 to 18 hours later, when Mr. Romero made his custodial

interrogation statements to Agent Waite. A sufficient quantity of evidence exists in the

record to persuade a fair-minded, rational person that Mr. Romero received fully

effective Miranda warnings and knowingly, intelligently, and voluntarily waived his

Miranda rights before making his statements. Substantial evidence supports the CrR

3.5 factual findings. The trial court did not err in admitting Mr. Romero's custodial

interrogation statements to Agent Waite.

B. Evidence Sufficiency

The issue is whether sufficient evidence supports Mr. Romero's conviction for

possessing a firearm without an alien firearm license. He contends the State did not

prove he lacked the license.

The State must prove all essential elements of a charged crime beyond a

reasonable doubt. In re Winship, 397 U.S. 358, 364, 90 S. Ct. 1068,25 L. Ed. 2d 368 (1970). Evidence is sufficient to support a guilty finding if '''after viewing the evidence in

the light most favorable to the prosecution, any rational trier of fact could have found the

essential elements of the crime beyond a reasonable doubt.'" State v. Green, 94 Wn.2d

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
In Re WINSHIP
397 U.S. 358 (Supreme Court, 1970)
Jackson v. Virginia
443 U.S. 307 (Supreme Court, 1979)
Rhode Island v. Innis
446 U.S. 291 (Supreme Court, 1980)
Wyrick v. Fields
459 U.S. 42 (Supreme Court, 1982)
Colorado v. Connelly
479 U.S. 157 (Supreme Court, 1986)
Thompson v. Keohane
516 U.S. 99 (Supreme Court, 1995)
Roger Maguire v. United States
396 F.2d 327 (Ninth Circuit, 1968)
Adinortey E. Puplampu v. United States
422 F.2d 870 (Ninth Circuit, 1970)
State v. Blanchey
454 P.2d 841 (Washington Supreme Court, 1969)
State v. Hill
870 P.2d 313 (Washington Supreme Court, 1994)
State v. Green
616 P.2d 628 (Washington Supreme Court, 1980)
State v. Salinas
829 P.2d 1068 (Washington Supreme Court, 1992)
State v. Broadaway
942 P.2d 363 (Washington Supreme Court, 1997)
State v. Campos-Cerna
226 P.3d 185 (Court of Appeals of Washington, 2010)
State v. Carver
789 P.2d 306 (Washington Supreme Court, 1990)
State v. Broadaway
133 Wash. 2d 118 (Washington Supreme Court, 1997)
State v. Campos-Cerna
154 Wash. App. 702 (Court of Appeals of Washington, 2010)

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