State Of Washington v. James E. Mitchell

CourtCourt of Appeals of Washington
DecidedAugust 29, 2017
Docket48810-8
StatusUnpublished

This text of State Of Washington v. James E. Mitchell (State Of Washington v. James E. Mitchell) 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 E. Mitchell, (Wash. Ct. App. 2017).

Opinion

Filed Washington State Court of Appeals Division Two

August 29, 2017

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 48810-8-II

Respondent,

v. UNPUBLISHED OPINION

JAMES EDWARD MITCHELL,

Appellant.

MAXA, A.C.J. – James Mitchell appeals his conviction of first degree premeditated

murder for stabbing a woman to death. Mitchell was convicted over 20 years after the crime

based on DNA (deoxyribonucleic acid) testing of blood evidence collected at the crime scene.

We hold that (1) the trial court properly admitted the DNA evidence because the State

showed a sufficiently complete chain of custody of the blood evidence collected at the crime

scene and any discrepancies affected the weight of the evidence rather than its admissibility, (2)

the State presented sufficient evidence of premeditation, and (3) the trial court did not err by

including Mitchell’s Florida robbery conviction in his offender score because it was comparable

to robbery in Washington.

Accordingly, we affirm Mitchell’s conviction of first degree premeditated murder and his

sentence. No. 48810-8-II

FACTS

In 2015, the State charged Mitchell with first degree murder for the stabbing death of

Linda Robinson. Robinson’s death had occurred over 20 years earlier, in 1993.

Robinson’s Death

On the night of February 6, 1993, Robinson’s young nieces and nephew were spending

the night at Robinson’s apartment. The oldest niece was seven years old, and the other two

children were approximately two and one. The children were in the living room.

Around 10:30 PM that night, Robinson was talking on the telephone with her friend

George Caldwell. Robinson told Caldwell to “Hold on, somebody’s at the door.” Report of

Proceedings (RP) at 654. Then Caldwell heard Robinson talking to another person and said

Robinson sounded “submissive,” telling the person “okay, okay.” RP at 655. But then the

connection went dead.

Around 11:00 PM, the oldest child was awakened by the sound of the apartment’s smoke

alarm. She went to the kitchen where she saw food burning on the stove and Robinson lying on

the kitchen floor surrounded by blood. A neighbor called the police.

Crime Investigation

The autopsy showed that Robinson had 10 stab wounds in her back. Multiple stab

wounds penetrated her chest cavity and punctured her lung and liver. Robinson had significant

amounts of blood in her chest cavity from her stab wounds. She also had defensive wounds on

her hands and forearms and superficial cuts to her chest and torso. The shape of some of the

wounds indicated that the likely cause was a single edged knife with a four inch blade. Police

never found the murder weapon.

2 No. 48810-8-II

Police and forensic investigators searched Robinson’s apartment for evidence. Robinson

was lying on the floor in the kitchen. Her pants pockets seemed to be turned out and between her

legs were a set of keys, a receipt, and a nickel. The telephone was about four feet away from her

and the cord was cut or torn from the wall. In Robinson’s bedroom, a dresser drawer was open.

Investigators collected blood evidence. There was blood on Robinson and around the

kitchen, including a large blood smear on the refrigerator. There was a small smear of blood on

the hallway wall across from the bathroom door. There were also blood spatters in front of a

nightstand in Robinson’s bedroom. The investigators took possession of the telephone from the

kitchen and a jacket from the bedroom that appeared to have blood on it.

At the time, none of the evidence was tested for DNA because the science had not yet

been developed to allow for DNA analysis of blood. Detectives were unable to identify a

suspect or solve Robinson’s murder.

In 2013, a detective reopened Robinson’s case and arranged to have the blood evidence

tested for DNA. Using a controlled sample of Robinson’s blood from her autopsy, forensic

scientists created Robinson’s DNA profile. They then tested the blood samples taken from the

bedroom, the jacket, the telephone cord, and Robinson’s jeans. DNA from an unknown

individual was present in the blood, and the DNA profile for that individual matched Mitchell’s

DNA profile. Mitchell was located in Florida, where he was arrested on charges of first degree

premediated murder and brought to Washington for trial.

Motion to Exclude Blood and DNA Evidence

Mitchell filed a pretrial motion to exclude the DNA evidence based on an insufficient

chain of custody. The trial court held a hearing on the issue, and several witnesses testified. The

3 No. 48810-8-II

court found that blood evidence was collected from the crime scene, stored in the sheriff’s

department forensics lab for 65 days, and then transferred to the sheriff’s department property

room. Robinson’s clothing was originally collected by the medical examiner and then

transferred to the sheriff’s department property room four days later.

The trial court ruled that the State had established the chain of custody and therefore that

the DNA evidence was admissible. The court ruled that any discrepancies in the chain of

custody related to the weight of the evidence, not its admissibility. The court entered findings of

fact and conclusions of law regarding its ruling.

Trial

Mitchell testified at trial that he knew Robinson and had been at her apartment a few

times. The last time he was there some kids were asleep in the living room. He said that while

he was with Robinson, she answered a knock at the door. An agitated man entered the apartment

and tried to hit Robinson and Mitchell. Mitchell said that Robinson tried to get the man to leave

and threatened to call the police, but the man stayed and exchanged blows with Mitchell.

According to Mitchell, the man left after Robinson again told him to leave. Then

Mitchell followed Robinson to her bedroom and looked at himself in her dresser mirror. He later

noticed that his hand was bleeding. Mitchell left the apartment and did not see Robinson again.

He denied killing Robinson.

The jury found Mitchell guilty of first degree premeditated murder.

Sentencing

The State calculated Mitchell’s offender score as 8, based on seven prior felony

convictions. One of the prior felonies was a 1983 armed robbery committed in Florida. Mitchell

4 No. 48810-8-II

argued that the Florida robbery should be excluded from his offender score because it was not

comparable to a Washington felony. The trial court ruled that the Florida robbery was

comparable and found that Mitchell’s offender score was 8. The trial court imposed a standard

range sentence of 450 months.

Mitchell appeals his conviction and sentence.

ANALYSIS

A. ADMISSIBILITY OF DNA EVIDENCE

Mitchell argues that the trial court should have excluded the DNA evidence because the

State failed to sufficiently establish the chain of custody of the blood evidence collected at the

crime scene. We disagree.

1. Legal Principles

Under ER 901(a), the proponent of evidence must authenticate or identify it “to support a

finding that the matter in question is what its proponent claims.” For physical evidence

connected to the commission of a crime to be admissible, “it must be satisfactorily identified and

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