State Of Washington v. Helen M. Dahll

CourtCourt of Appeals of Washington
DecidedMarch 1, 2021
Docket80065-5
StatusUnpublished

This text of State Of Washington v. Helen M. Dahll (State Of Washington v. Helen M. Dahll) 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. Helen M. Dahll, (Wash. Ct. App. 2021).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION ONE STATE OF WASHINGTON, ) No. 80065-5-I ) Respondent, ) ) v. ) ) HELEN M. DAHLL, ) UNPUBLISHED OPINION ) Appellant. ) )

VERELLEN, J. — Helen Dahll assigns error to her convictions for first

degree theft and attempted first degree theft. She contends the court erred by

excluding evidence, the State prejudiced her right to a fair trial by mismanaging

discovery, and the State failed to disprove her good faith claim of title defense

to the money she was charged with stealing from her elderly father, John Dahll.1

Helen fails to show the court abused its discretion by concluding her

father’s will was irrelevant to her right to his money before his death and by

concluding the probative value of the foreclosure of her home after the charging

period did not outweigh its emotional impact.

1 Because they have the same last name, we refer to John and Helen Dahll by their first names. No. 80065-5-I/2

She also fails to prove actual prejudice from discovery mismanagement

by the State because evidence timely disclosed revealed the same information

and would have let her attorney pose the same theory she now argues was

unavailable to her.

And she fails to demonstrate the State presented insufficient evidence to

disprove her defense of an open and avowed taking of her father’s money

under a good faith claim of title.

Therefore, we affirm.

FACTS

In April of 2012, Helen became a caregiver for her elderly father John

and, after a power of attorney he had signed years earlier took effect, became

his attorney-in-fact. John was in the early stages of dementia and suffered from

heart disease, congestive heart failure, and arthritis in his knees, among other

health problems. Helen hired a home healthcare provider, and John began

receiving 24-hour care in his house.

In the spring of 2014, John moved in with Helen, and she rented out his

house. She reduced his caretaking hours to only four per day. By this time, he

was unable to toilet himself, prepare meals, manage his medications, or get

around independently. Helen’s neighbors began noticing she often went out for

hours and left John alone. Helen would leave the front door unlocked when she

went out, so her neighbors would check on John. More than once, a neighbor

found John lying on the floor and calling out for Helen, unaware she had left him

2 No. 80065-5-I/3

alone. As more neighbors became concerned for John’s welfare, they

submitted reports to Adult Protective Services (APS).

On October 8, 2015, an APS investigator visited John. She noticed his

limited cognitive abilities, such as not knowing the date or time, not knowing

who was visiting him, not knowing how long Helen left him alone, and being

unaware he was unable to care for himself. She returned again on November 4

after a home healthcare worker arrived to find John cold, shivering, and

precariously positioned in his bed.

On November 14, the APS investigator returned to check on John, and

Helen refused to let her in, relenting only after the police arrived. The

investigator found John lying in his own waste and wearing clothes stained with

urine and blood. He had a bright red sore on his tailbone and a bloody wound

on his buttocks. Helen said she knew he needed 24-hour care but could not

afford it because John had only $15,000 in certificates of deposit and no

savings. She said his only income was from his Boeing pension and from

renting out his house. Helen had not worked in over 10 years due to her own

medical issues, and John had financially supported her.

John was moved into an adult family home in November of 2015. On

February 3, 2016, an independent guardian was appointed, over Helen’s

objection, for John’s person and estate. The appointment ended Helen’s role

as John’s attorney-in-fact. The guardian reviewed John’s finances and

discovered at least $200,000 missing from his checking and savings accounts,

3 No. 80065-5-I/4

all of which were at BECU. The guardian called the police. John died on

September 15, 2016, and the guardian became personal representative of his

estate.

Helen was charged with committing first degree theft between April 1,

2014 and February 22, 2016, attempted first degree theft between March 22

and 23, 2016, and third degree criminal mistreatment between June 1, 2015

and November 16, 2015. The State’s theory was that Helen took John’s money

through many unauthorized automated teller machine (ATM) withdrawals.

Helen’s pretrial theory was that she spent the missing money both on John’s

care and to support herself, which he had intended for her to do by making her

a joint accountholder. The court excluded evidence that John had made Helen

the primary beneficiary of his estate and that Helen’s home was in foreclosure

at the time of trial.

In the middle of trial, the records officer for BECU provided documents to

the State that had not been disclosed previously. Account documents showed

several accounts identified as Helen’s alone were actually joint accounts held

by Helen and John. Helen moved to dismiss under CrR 8.3(b), arguing the late

disclosures were prejudicial discovery violations caused by governmental

misconduct. The court denied her motion. The jury found Helen guilty of all

charges.

Helen appeals, assigning error to only the theft and attempted theft

convictions.

4 No. 80065-5-I/5

ANALYSIS

I. Evidentiary Rulings

Helen contends her right to present a defense was violated by the court

excluding two pieces of evidence. We review a court’s evidentiary decisions for

abuse of discretion and review de novo whether the defendant’s right to present

a defense was violated.2

She argues the court erred when it excluded relevant evidence from

John’s 1992 will designating her as the primary beneficiary of his estate.

“‘To be relevant . . . evidence must (1) tend to prove or disprove the

existence of a fact, and (2) that fact must be of consequence to the outcome of

the case.’”3 The threshold for relevancy is very low, and even minimally

relevant evidence is admissible.4 Irrelevant evidence is inadmissible.5 A

defendant has no right to introduce inadmissible evidence.6

In 1992, John signed a will designating Helen the personal

representative and primary beneficiary of his estate if his wife Mary

2 State v. Bedada, 13 Wn. App. 2d 185, 194, 463 P.3d 125 (2020) (citing State v. Arndt, 194 Wn.2d 784, 797-98, 453 P.3d 696 (2019); State v. Clark, 187 Wn.2d 641, 648-56, 389 P.3d 462 (2017)). 3 State v. Weaville, 162 Wn. App. 801, 818, 256 P.3d 426 (2011) (alteration in original) (quoting Davidson v. Municipality of Metro. Seattle, 43 Wn. App. 569, 573, 719 P.2d 569 (1986)). 4 State v. Briejer, 172 Wn. App. 209, 225, 289 P.3d 698 (2012) (quoting State v. Darden, 145 Wn.2d 612, 621, 41 P.3d 1189 (2002)). 5 ER 402. 6 Bedada, 13 Wn. App. 2d at 193 (citing State v. Blair, 3 Wn. App. 2d 343, 349, 415 P.3d 1232 (2018)).

5 No. 80065-5-I/6

predeceased him. The court allowed evidence John designated Helen as his

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Johnson
950 P.2d 981 (Court of Appeals of Washington, 1998)
In Re Estate of Wiltermood
472 P.2d 536 (Washington Supreme Court, 1970)
State v. Hicks
683 P.2d 186 (Washington Supreme Court, 1984)
Davidson v. Municipality of Metropolitan Seattle
719 P.2d 569 (Court of Appeals of Washington, 1986)
State v. Blackwell
845 P.2d 1017 (Washington Supreme Court, 1993)
Willis v. Estate of Tosh
920 P.2d 1230 (Court of Appeals of Washington, 1996)
State v. Dailey
610 P.2d 357 (Washington Supreme Court, 1980)
Matter of Estate of Baird
933 P.2d 1031 (Washington Supreme Court, 1997)
State v. Ager
904 P.2d 715 (Washington Supreme Court, 1995)
State v. Kendrick
736 P.2d 1079 (Court of Appeals of Washington, 1987)
State v. Hudlow
659 P.2d 514 (Washington Supreme Court, 1983)
State v. WEAVILLE
256 P.3d 426 (Court of Appeals of Washington, 2011)
State v. Brooks
203 P.3d 397 (Court of Appeals of Washington, 2009)
State v. Rohrich
71 P.3d 638 (Washington Supreme Court, 2003)
State v. Thomas
208 P.3d 1107 (Washington Supreme Court, 2009)
State v. Hosier
133 P.3d 936 (Washington Supreme Court, 2006)
State v. Darden
41 P.3d 1189 (Washington Supreme Court, 2002)
State v. Mora
43 P.3d 38 (Court of Appeals of Washington, 2002)
State v. Jones
230 P.3d 576 (Washington Supreme Court, 2010)
State v. Thomas
83 P.3d 970 (Washington Supreme Court, 2004)

Cite This Page — Counsel Stack

Bluebook (online)
State Of Washington v. Helen M. Dahll, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-helen-m-dahll-washctapp-2021.