State of Washington v. Jeremy Michael Lowrey

CourtCourt of Appeals of Washington
DecidedOctober 4, 2022
Docket38365-2
StatusUnpublished

This text of State of Washington v. Jeremy Michael Lowrey (State of Washington v. Jeremy Michael Lowrey) 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. Jeremy Michael Lowrey, (Wash. Ct. App. 2022).

Opinion

FILED OCTOBER 4, 2022 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STATE OF WASHINGTON, ) ) No. 38365-2-III Respondent, ) ) v. ) UNPUBLISHED OPINION ) JEREMY MICHAEL LOWREY, ) ) Appellant. )

STAAB, J. — Jeremy Lowrey was charged with five counts of first degree

possession of depictions of minors engaged in sexually explicit conduct and one count of

second degree possession of depictions of minor engaged in sexually explicit conduct.

Lowrey testified at trial that he was investigating child pornography for the police.

During closing argument, the State made an incomplete comment about societal

expectations and mistakenly stated the number of explicit images located by police.

Lowrey objected, and the trial court sua sponte gave curative instructions. On appeal,

Lowrey raises issues of prosecutorial misconduct and ineffective assistance of counsel.

We affirm. Lowrey fails to demonstrate misconduct, and the trial court’s instructions No. 38365-2-III State v. Lowrey

cured any error. Defense counsel was not ineffective for failing to request additional

instructions.

In his statement of additional grounds (SAG), Lowrey contends that his inability

to review the electronic discovery with his attorney impacted his ability to provide a valid

defense. Because this issue is not developed on the record, we decline to review it.

BACKGROUND

After receiving a tip from the National Center for Missing and Exploited Children

indicating that multiple images of child pornography had been identified on a specific

local internet protocol (IP) address, Detective Jennifer Margheim obtained a search

warrant to identify the person to whom the IP address was registered. After pinpointing

Lowrey, she obtained a second warrant to search Lowrey’s residence. Detective Matt

Martin testified at trial that Lowrey’s computer contained over 3,000 videos and 67,186

exploitive images of children. Fifteen of these images were admitted as evidence and

shown to the jury. Lowrey testified that he collected the images for eight years to help

police “investigate.” He did not provide evidence of law enforcement credentials and

acknowledged that he never communicated any of the images to the police. Defense

counsel argued this theory in closing.

The jury found Lowrey guilty of five counts of first degree possession of

depictions of minors engaged in sexually explicit conduct under RCW 9.68A.070(1) and

2 No. 38365-2-III State v. Lowrey

one count of second degree possession of depictions of minor engaged in sexually

explicit conduct under RCW 9.68A.070(2)(a) and (b).

On appeal, Lowrey focuses on the State’s closing argument. In closing, the State

argued:

There’s a word that we use a lot in this courtroom and in the statutes and in the laws of the State of Washington and that word is reasonable. Because we have presumption of society that those of us that are a member of our society are reasonable people. We actually expect people to be reasonable. We expect people to do what’s right, to do the right things. And we have laws that are enacted to take action when people do things that are not reasonable. We are here today because it is not reasonable for Jeremy Lowrey to be a one man police investigation crew of child pornography on the internet. You can believe every word he said while he was testifying and still find him guilty, because his actions are not reasonable. We have to be careful not to decide cases based on sympathy or emotion or prejudice. And so, I’d like to discuss the images with you, not to inflame your emotions or prejudice but in the context of what Mr. Lowrey is saying was reasonable. You and I sat in this courtroom and Detective Margheim and Detective Martin looked through, they looked through thousands of images of kids being raped.

Report of Proceedings (RP) at 271-72. Defense counsel objected to mischaracterization

of the evidence. The court sustained the objection and instructed the jury to “recall what

the actual testimony was.” RP at 272.

The State went on to argue:

They looked through thousands of images. 96,000 images of children being raped, abused, molested, exploited. And you and I sat in the courtroom and we looked at 15. Difficult to look at. We expect as a society that when somebody sees a picture of a five year old or less with

3 No. 38365-2-III State v. Lowrey

her buttocks spread and another little girl licking her anus, we expect as a society that—

RP at 272. Defense counsel objected, asserting that the State was suggesting that the

defendant should be punished because of societal norms, and the State had to “argue her

case.” RP at 272. The court sustained the objection and instructed the jury to follow jury

instructions and “have in mind the Instructions that have been read and the evidence that

has been presented.” RP at 272-73.

The State continued:

And moving to my second point, you don’t have to believe anything Mr. Lowrey told you because whether you believe him or not, it’s not credible. One time? Maybe. You accidentally get something that you’re like ooh, this is bad. We’re not talking about one time. We’re talking about 96,000 images and we’re talking about 15 specific images that are on a device that he admits using. They come into his possession because he’s clicking these random downloads and then he downloaded them on his computer and then they’re there. He’s—we’re not even talking about you or me or some, you know, internet novice. We’re talking about somebody that is incredibly tech savvy, knows exactly how systems and computers and analysis of computers and data management systems. He’s a problem solver. That’s his job. Is it reasonable to think that the [crime] problem for him to solve is child exploitation sexual materials on the internet? Absolutely not. We have entire agencies devoted to that and he did nothing. He sent a report—

RP at 274. Defense counsel again objected to this statement as a mischaracterization of

the evidence, which the court overruled before instructing the jury to recall the exact

evidence. The State proceeded to argue that Lowrey’s explanation of his actions for eight

years was not reasonable, credible, or believable.

4 No. 38365-2-III State v. Lowrey

ANALYSIS

A. PROSECUTORIAL MISCONDUCT

The first issue raised by Lowrey is whether the State committed prosecutorial

misconduct in closing argument by (1) mischaracterizing the burden of proof as a

violation of societal expectations rather than proof of the charged crime beyond a

reasonable doubt, and (2) appealing to the passions of the jury by arguing that the jury

viewed more images than appeared as exhibits. At trial, Lowrey’s attorney made three

objections during the State’s closing argument. His first and third objections were that

the State was mischaracterizing the evidence when it argued: “You and I sat in this

courtroom and Detective Margheim and Detective Martin looked through, they looked

through thousands of images of kids being raped—” RP at 272, and again when the State

argued that “we have entire agencies devoted to that and he did nothing. He sent a

report.” RP at 274. Lowrey also objected, indicating that the State was asking the jury to

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