State of Washington v. Ian Jonathan Anderson

CourtCourt of Appeals of Washington
DecidedJune 21, 2016
Docket33141-5
StatusUnpublished

This text of State of Washington v. Ian Jonathan Anderson (State of Washington v. Ian Jonathan Anderson) 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. Ian Jonathan Anderson, (Wash. Ct. App. 2016).

Opinion

FILED June 21, 2016 In the Office of the Clerk of Court WA State Court of Appeals, Division Ill

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON DIVISION THREE

STATE OF WASHINGTON, ) No. 33141-5-111 ) Respondent, ) ) V. ) UNPUBLISHED OPINION ) IAN JONATHAN ANDERSON, ) ) Appellant. )

LAWRENCE-BERREY, J. - Ian Anderson appeals his conviction for possession of a

stolen vehicle. He argues the trial court violated his right to a public trial and his right to

be present at all critical stages when it directed a court staff member to speak with a

venire juror outside of the courtroom to determine if his civil right to be a juror had been

restored after his felony conviction. Mr. Anderson also argues the trial court abused its

discretion by allowing evidence of his flight, resisting arrest, and being subdued by a stun

gun, and this error was not harmless. Mr. Anderson further argues the trial court erred by

imposing legal financial obligations (LFOs). In his statement of additional grounds for

review (SAG), Mr. Anderson argues the State introduced irrelevant and prejudicial

evidence at trial and also failed to prove he knew the vehicle was stolen. We disagree No. 33141-5-III State v. Anderson

with Mr. Anderson's constitutional, LFO, and SAG arguments. We agree that allowing

evidence of his being subdued by a stun gun was an abuse of discretion, but determine the

error to be harmless. We, therefore, affirm.

FACTS

Bryan Dugdale had a green Nissan Maxima with Montana license plates. Mr.

Dugdale did not use the car but kept it behind his apartment. Mr. Dugdale's father, a

Montana resident, was the car's registered owner.

In June 2014, Mr. Dugdale arranged to sell the Maxima to his neighbor. Mr.

Dugdale removed the registration from the car and locked it. On the morning of June 23,

2014, Mr. Dugdale's neighbor sent him a text asking where the Maxima was. It was then

that Mr. Dugdale learned that the car was recently stolen, and he reported the theft to the

Spokane Police Department.

On June 24, 2014, Spokane Police Sergeant Kurt Vigesaa was on patrol when he

saw a green Maxima with Montana license plates. The sergeant recalled that a vehicle

with a similar description had been reported stolen. He confirmed the car matched the

one reported stolen and then followed the Maxima until backup could assist him. He saw

the Maxima's driver tum into a parking lot and park the car. The sergeant then parked his

patrol car behind the Maxima to prevent the driver from fleeing in the car.

2 No. 33141-5-III State v. Anderson

Sergeant Vigesaa instructed the driver, later identified as Mr. Anderson, to remain

in the car with his hands on the steering wheel. The sergeant told Mr. Anderson the

Maxima had been reported stolen. Mr. Anderson replied he was just borrowing it.

When backup arrived, Sergeant Vigesaa instructed Mr. Anderson to step out of the

car. The sergeant then instructed Mr. Anderson to tum and face the Maxima and sidestep

toward the rear of the vehicle. Mr. Anderson complied with the sergeant's instructions.

But when the sergeant instructed Mr. Anderson to place his hands behind his back, Mr.

Anderson fled.

As Mr. Anderson fled past one of the officers, the officer grabbed him and forced

him to the ground. Mr. Anderson continued to resist. Up to four officers assisted in

trying to subdue him. The officers informed Mr. Anderson he was under arrest and to

stop resisting. Mr. Anderson continued to struggle until an officer deployed a stun gun.

The State charged Mr. Anderson with one count of possession of a stolen motor

vehicle. Prior to jury selection, each venire juror received an identification number. The

State notified the trial court that venire juror 31 had a prior felony conviction, and it was

unclear if the juror's civil rights had been restored so he could serve as a juror. The trial

court suggested that a court staff member speak with juror 3 1 outside the courtroom and

determine his status. The trial court further suggested, if juror 31 told the staff member

3 No. 33141-5-III State v. Anderson

his rights had not been restored, or he was unsure, the trial court would excuse juror 31.

Neither the State nor Mr. Anderson objected to the trial court's suggestions. The court

staff member presumably spoke with juror 31, but a summary of the discussion was not

placed on the record. According to a clerk's notation, juror 31 was struck for cause.

The jury found Mr. Anderson guilty of possession of a stolen motor vehicle. At

sentencing, the trial court imposed LFOs on Mr. Anderson. These LFOs consist of a

$500 victim assessment fee, a $200 criminal filing fee, and a $100 deoxyribonucleic acid

(DNA) collection fee. The trial court stated it would waive these fines and costs but it

could not. Mr. Anderson appeals.

ANALYSIS

A. Right to a public trial

Defendants have a constitutional right to a public trial. U.S. CONST. amend. VI;

CONST. art. I, § 22. A violation of the public trial right can be raised for the first time on

appeal. State v. Wise, 176 Wn.2d 1, 9, 288 P.3d 1113 (2012). Failure to object at trial

does not constitute a waiver of a defendant's public trial right. State v. Shearer, 181

Wn.2d 564, 569, 334 P.3d 1078 (2014). Violation of a defendant's public trial right is a

question of law reviewed de novo. Wise, 176 Wn.2d at 9 ( quoting State v. Easterling,

157 Wn.2d 167, 173-74, 137 P.3d 825 (2006)).

4 No. 33141-5-III State v. Anderson

The right to a public trial is not absolute. Shearer, 181 Wn.2d at 569. Competing

rights and interests often require trial courts to limit public access to a trial. Id. Trial

courts assess these competing interests by using the five factor analysis articulated in

State v. Bone-Club, 128 Wn.2d 254, 258-59, 906 P.2d 325 (1995). A trial court must

consider the five Bone-Club factors on the record before closing the courtroom. Wise,

176 Wn.2d at 10. Closing the courtroom without considering the Bone-Club factors is

structural error and is presumed to be prejudicial. Shearer, 181 Wn.2d at 569.

However, before determining if a public trial right violation has occurred, this

court must first determine whether the court proceeding implicates the right. State v.

Sublett, 176 Wn.2d 58, 71, 292 P.3d 715 (2012). The Washington Supreme Court has

adopted the "experience and logic" test developed by the United States Supreme Court to

determine if a court proceeding implicates the public trial right. Id. at 72-75. The

"experience prong" asks "' whether the place and process have historically been open to

the press and general public.'" Id. at 73 (quoting Press-Enterprise Co. v. Superior Court,

478 U.S. 1, 8, 106 S. Ct. 2735, 92 L. Ed. 2d 1 (1986)). The "logic prong" asks "'whether

public access plays a significant positive role in the functioning of the particular process

in question."' Id. (quoting Press-Enterprise Co., 478 U.S. at 8). If both questions are

answered yes, then the court proceeding implicates the public trial right. Id.

5 No. 33141-5-III State v. Anderson

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