State Of Washington v. James A. Bitner

CourtCourt of Appeals of Washington
DecidedJune 25, 2019
Docket51179-7
StatusUnpublished

This text of State Of Washington v. James A. Bitner (State Of Washington v. James A. Bitner) 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. James A. Bitner, (Wash. Ct. App. 2019).

Opinion

Filed Washington State Court of Appeals Division Two

June 25, 2019

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 51179-7-II

Respondent, UNPUBLISHED OPINION v.

JAMES ANTHONY BITNER,

Appellant.

MAXA, C.J. – James Bitner appeals his conviction for delivery of a controlled substance –

methamphetamine. The State charged Bitner after law enforcement directed a confidential

informant (CI) to purchase methamphetamine from him. The CI was unavailable to testify at

Bitner’s trial, but the trial court admitted into evidence her text message exchange with Bitner

setting up the details of the transaction.

We hold that (1) the trial court did not err in admitting the CI’s text messages as

authenticated under ER 901 because the detective who testified had sufficient knowledge to

authenticate them; (2) the trial court’s admission of the text messages did not violate Bitner’s

confrontation right because they did not constitute hearsay; (3) Bitner’s Statement of Additional

Grounds (SAG) claims lack merit; and (4) the DNA collection fee imposed on Bitner must be

stricken because his DNA previously was collected in connection with another conviction, but

the trial court must determine if the criminal filing fee should be stricken based on Bitner’s

indigence. No. 51179-7-II

Accordingly, we affirm Bitner’s conviction, but we remand for the trial court to strike the

DNA collection fee and to determine for purposes of the criminal filing fee whether Bitner was

indigent as defined in RCW 10.101.010(3)(a)-(c).

FACTS

On August 24, 2016, Centralia police detective Chad Withrow directed a CI to arrange to

purchase methamphetamine from Bitner at approximately 1:00 or 1:30 that afternoon. The CI

also was going to purchase methamphetamine from others at Withrow’s direction.

Withrow met with the CI after directing her to target Bitner. Withrow observed the CI

sending and receiving texts indicating that the recipient was ready to complete the deal. The CI

also showed Withrow prior texts in the same thread consistent with his instructions, arranging

the deal for 1:30 PM at a KFC location in Centralia and setting the price for a “ball” –

approximately 3.5 grams – at $100. Withrow read and took photographs of these text messages.

The text messages Withrow photographed read as follows:

[CI:] Will u be in town around 1? And do u got a ball? 11:21 AM

Yes an [sic] yes 11:21 AM

[CI:] Would u be able to meet me at kfc? 11:22 AM

[CI:] Im [sic] splitting it with someone and tell me the price 11:22 AM

Yes of corse [sic] 11:22 AM

[CI:] Okay 11:22 AM

100 11:23 AM

2 No. 51179-7-II

[CI:] K 11:24 AM

[CI:] About a half hour 12:26 PM

[CI:] 1:30ish 12:37 PM

U ready 1:20 PM

[CI:] Yeah I will be just a few I had to pick up the $ 1:20 PM

[CI:] Im [sic] hurrying 1:20 PM

Ok 1:21 PM

[CI:] Omw 1:27 PM

Ok 1:27 PM

Exs. 23, 24, 25.

Before the CI left to meet with Bitner, officers conducted a strip search of her and

searched her purse. They determined she had not brought any contraband items with her.

Officers gave the CI buy funds and dropped her off near the KFC at about 1:33 PM. The CI

walked the remaining distance to the KFC parking lot under police surveillance.

Two officers conducting surveillance of the KFC parking lot from across the street

observed Bitner arrive at the KFC shortly before 1:30 PM, before the CI. Bitner went into the

KFC. While he was inside, the CI arrived at the KFC parking lot at approximately 1:35 PM and

stood at the passenger door of Bitner’s car. Bitner exited the KFC and entered his car on the

3 No. 51179-7-II

driver’s side while the CI entered on the passenger side. The CI exited Bitner’s car less than a

minute later.

After exiting Bitner’s car, the CI returned directly to a police van one block away. She

produced a bag containing approximately 3.5 grams of a substance later determined by the police

to be methamphetamine. Police then conducted a second strip search of the CI. They did not

find the money detectives had provided to her earlier to complete the buy.

The State subsequently charged Bitner with delivery of methamphetamine with a

sentencing enhancement for committing the offense within 1,000 feet of a school bus stop.

At trial, the State was unable to locate the CI to testify. Bitner moved to exclude the

photographs of the CI’s text messages regarding the drug purchase based on ER 901 and on his

rights under the confrontation clause. As an offer of proof, the State indicated that Withrow

would testify that he saw the text message exchange on the CI’s phone and took photographs of

the exchange. The State also referenced evidence that Bitner was the person that appeared at

KFC at approximately 1:30 PM as discussed in the text messages.

The trial court ruled that the photographs of the text messages were authenticated and that

Withrow could testify about what he saw and about what the text messages said. However, the

court ruled that the State could not produce evidence from the text messages that identified

Bitner’s name and number. The court also ruled that Withrow could testify only what the text

messages said, not that the text messages were from Bitner. Finally, the court ruled that the text

messages were not testimonial and therefore did not violate the confrontation clause.

Bitner’s first trial ended in a mistrial because the jury panel was tainted during voir dire.

Before the second trial, Bitner asked the court to revisit the text message issue but did not assert

4 No. 51179-7-II

a confrontation clause argument at that time. The court maintained its prior rulings regarding

admissibility.

At trial, Withrow testified as recited above about reading and photographing the text

messages. He testified that the CI sent and received the text messages, but he did not testify that

Bitner was the person texting with the CI. The trial court admitted the text message exchange as

exhibits over Bitner’s objection.

The jury found Bitner guilty of delivery of a controlled substance with a school bus stop

sentencing enhancement. Bitner appeals his conviction.

ANALYSIS

A. AUTHENTICATION OF TEXT MESSAGES

Bitner argues that the trial court erred in admitting the text messages because no witness

testifying at trial had the requisite knowledge to authenticate them under ER 901. We disagree.

1. Legal Principles

Before a trial court admits evidence, ER 901(a) requires that the proponent authenticate it

with “evidence sufficient to support a finding that the matter in question is what its proponent

claims.” See State v. Bashaw, 169 Wn.2d 133, 140-41, 234 P.3d 195 (2010). To meet this

requirement, the proponent must make a prima facie showing sufficient to allow a reasonable

juror to find that the evidence is authentic. Id. We review a trial court’s admission of evidence

for abuse of discretion. State v. Young, 192 Wn. App. 850, 854, 369 P.3d 205 (2016).

ER 901(b) provides illustrative examples of authentication. These include testimony by a

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