State Of Washington v. John Michael Sanchez

CourtCourt of Appeals of Washington
DecidedJuly 21, 2020
Docket52916-5
StatusUnpublished

This text of State Of Washington v. John Michael Sanchez (State Of Washington v. John Michael Sanchez) 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. John Michael Sanchez, (Wash. Ct. App. 2020).

Opinion

Filed Washington State Court of Appeals Division Two

July 21, 2020

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 52916-5-II

Respondent,

v.

JOHN MICHAEL SANCHEZ, UNPUBLISHED OPINION

Appellant.

MELNICK, J. — John Sanchez appeals his conviction for tampering with a witness. He

argues that the trial court erred by denying a motion for a new trial after instructing the jury on an

uncharged alternative way of tampering with a witness. He argues he was prejudiced. The State

concedes the error but contends it was harmless. We agree with Sanchez and reverse.

FACTS

In June 2018, Sanchez, an inmate at the Thurston County Jail, had two unresolved cases.

The State listed Rachel Nickels, the mother of Sanchez’s two children, as a witness in both cases.

Jail staff believed that Sanchez would attempt to contact Nickels in violation of a no-contact order,

so they put a hold on any mail from Sanchez’s custody unit sent to Nickels’s address.

Lieutenant Jenny Hovda intercepted an envelope addressed to “Shiloh Princton” at

Nickels’s address. Clerk’s Papers (CP) at 128. The return address listed Kyle Baker, a “jail friend”

of Sanchez’s who was housed in the same custody unit. 1 Report of Proceedings (RP) at 104. The

envelope contained a letter and some drawings. Hovda recognized the handwriting on the letter

as Sanchez’s because Sanchez wrote multiple complaints to Hovda during his incarceration. 52916-5-II

Hovda also observed that the drawings were addressed to “Noah” and “Taj.” 1 RP at 156. Hovda

knew from listening to approximately 100 hours of Sanchez’s calls at the jail that his children were

named Noah and Taj.

The letter stated in relevant part, “As long as you don’t cooperate, they will drop a lot of

this stuff. I will still have to plea to something” and, “I’ve been here way too long. I need to be

released now. You need to help in that by not cooperating or returning calls and not [unreadable].”

1 RP at 155.1 Nickels identified the author as Sanchez based on the handwriting, the drawings,

the content of the letter, and the way the author signed the letter as “[her] soulmate.” 2 RP at 222.

The State charged Sanchez with one count of witness tampering. The information alleged

that he “attempted to induce Rachel Nickels . . . a witness or person he or she has reason to believe

is about to be called as a witness in any official proceeding or a person whom he or she has reason

to believe may have information relevant to a criminal investigation or the abuse or neglect of a

minor child to testify falsely or, without right or privilege to do so, to withhold any testimony.”

CP at 1.

Sanchez proposed a “to convict” instruction that, as relevant here, limited the means of

committing witness tampering to inducing a witness to “testify falsely or withhold testimony,” the

only alternative charged by the State. 2 RP at 242; CP at 89.

1 Hovda read portions of the letter during the State’s case: “There’s a sentence, ‘As long as you don’t cooperate, they will drop a lot of this stuff. I will still have to plea a something, but at least it’s not’ and I can’t read the writing on that part.” And “Then ‘I’ve been here way too long. I need to be released now. You need to help in that by not cooperating or returning calls and not’—and again, I can’t read the writing.” 1 RP at 155. When the State read the same portions of the letter during closing, it added “but at least it’s not ten to life-er” to the end of the first statement, and “or returning calls and not testifying” to the end of the second one. 2 RP at 270.

2 52916-5-II

The court drafted its own jury instructions for the parties to review. The court asked for

objections and exceptions. After the parties reviewed the instructions given by the court, Sanchez

neither objected nor excepted.

The court’s draft included the State’s “to convict” instruction which read:

To convict the defendant of the crime of tampering with a witness as charged, each of the following elements of the crime must be proved beyond a reasonable doubt: (1) That on or about June 15, 2018, the defendant attempted to induce Rachel Nickels to testify falsely, or without right or privilege to do so, withhold any testimony or absent herself from any official [proceeding]; and (2) That Rachel Nickels was a witness or a person the defendant had reason to believe was about to be called as a witness in any official proceedings; and. (3) That any of these acts occurred in the State of Washington. If you find from the evidence that each of these elements has been proved beyond a reasonable doubt, then it will be your duty to return a verdict of guilty. On the other hand, if, after weighing all of the evidence, you have a reasonable doubt as to any one of these elements, then it will be your duty to return a verdict of not guilty.

CP at 121 (Instr. 10).

Another jury instruction stated:

A person commits the crime of tampering with a witness when he or she attempts to induce a witness or person he or she has reason to believe is about to be called as a witness in any official proceeding to testify falsely or, without right or privilege to do so, to withhold any testimony or to absent himself or herself from any official proceedings.

CP at 118 (Instr. 7).

At trial, Sanchez primarily argued that he did not write the letter. As a result, witness

testimony and closing arguments from both parties focused on that issue, rather than whether the

language of the letter amounted to tampering. However, both Sanchez and the State discussed the

elements of witness tampering and both mentioned absenting oneself from the proceedings in

closing argument. After going through each element of the to convict instruction, the State argued

that the language of the letter showed an attempt “to induce [Nickels] not to testify.” It also argued

3 52916-5-II

that “There is no clearer way to ask somebody not to come to court to testify than saying you need

help in that by not cooperating or returning calls and not testifying.” 2 RP at 298-300.

The jury found Sanchez guilty.

Relying on CrR 7.5(a), Sanchez moved for a new trial based on the jury instruction

containing an uncharged alternative of committing witness tampering. The State conceded the

error but argued that it was harmless. The court agreed with the State and denied the motion.

Sanchez appeals.

ANALYSIS

“Except where questions of law are involved, a trial judge is invested with broad discretion

in granting motions for new trial. The exercise of that discretion will not be disturbed on appeal

absent an abuse of discretion.” State v. Williams, 96 Wn.2d 215, 221, 634 P.2d 868 (1981). When

a motion for a new trial is based on an alleged error of law, the trial court’s decision whether to

grant the motion is reviewed de novo. State v. Mohamed, 186 Wn.2d 235, 241, 375 P.3d 1068

(2016).

Sanchez argues that he was denied due process because the jury instructions included an

uncharged alternative of committing witness tampering. The State concedes error but argues it

was harmless. Sanchez argues that because the jury could have convicted him on uncharged

alternative, he has shown prejudice. We accept the State’s concession but agree with Sanchez that

the error was not harmless.

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Related

State v. Bray
756 P.2d 1332 (Court of Appeals of Washington, 1988)
State v. Williamson
924 P.2d 960 (Court of Appeals of Washington, 1996)
State v. Williams
634 P.2d 868 (Washington Supreme Court, 1981)
State v. Spiers
79 P.3d 30 (Court of Appeals of Washington, 2003)
State v. Chino
72 P.3d 256 (Court of Appeals of Washington, 2003)
State v. Laramie
169 P.3d 859 (Court of Appeals of Washington, 2007)
State v. Severns
125 P.2d 659 (Washington Supreme Court, 1942)
State v. Mohamed
375 P.3d 1068 (Washington Supreme Court, 2016)
State v. Chino
117 Wash. App. 531 (Court of Appeals of Washington, 2003)
State v. Spiers
79 P.3d 30 (Court of Appeals of Washington, 2003)
State v. Laramie
141 Wash. App. 332 (Court of Appeals of Washington, 2007)
State v. Lindsey
311 P.3d 61 (Court of Appeals of Washington, 2013)

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