State Of Washington v. Jose Ruiz-Alcala

CourtCourt of Appeals of Washington
DecidedDecember 2, 2014
Docket30944-4
StatusUnpublished

This text of State Of Washington v. Jose Ruiz-Alcala (State Of Washington v. Jose Ruiz-Alcala) 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. Jose Ruiz-Alcala, (Wash. Ct. App. 2014).

Opinion

FILED

December 2, 2014

In the Office of the Clerk of Court

W A State Court of Appeals, Division III

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION THREE

STATE OF WASHINGTON, ) No. 30944-4-111 ) Appellant, ) ) v. ) ) JOSE RUIZ-ALCALA, ) UNPUBLISHED OPINION ) Respondent. )

BROWN, A.C.J. - The State appeals the Yakima County Superior Court's decision

granting Jose Ruiz-Alcala a new trial based upon the court deciding he received

ineffective assistance of counsel. The court concluded Mr. Ruiz-Alcala did not receive a

fair trial because he was prejudiced by defense counsel's failure to object to the

admissibility of certain evidence and by mentioning a gun, all of which the court

reasoned was inadmissible. The State contends the court abused its discretion in

granting the new trial as all the evidence was relevant, admissible, part of a legitimate

trial strategy, and not prejudicial. We find no abuse of discretion, and affirm.

FACTS

In June 2011, the local drug task force aerially observed a large marijuana grow

operation near the Ahtanum Ridge area. Officers suspected an abandoned logging

road was a drop point for reaching the grow and placed surveillance cameras there. No. 30944-4-111 State v. Ruiz-Alcala

Review of the surveillance footage showed a pattern of vehicles arriving and dropping

off people on Fridays then returning to pick them up on Sundays. Detective Mark

Negrete obtained license plate numbers and still photographs of drivers' faces from the

footage. One vehicles was registered to Gerardo Alcala, Mr. Ruiz-Alcala's brother, but

the photograph of the vehicle's driver did not match Mr. Ruiz-Alcala's license.

On August 9, 2011, the marijuana grow was eradicated. The grow had 10,000 to

15,000 plants within two weeks of harvesting, the odor of marijuana was very strong,

and a campsite was found nearby. The following day, officers executed a search

warrant at the address seen on Mr. Alcala's registration. Officers found Mr. Ruiz-Alcala

there and identified him as the man in the photograph. Mr. Ruiz-Alcala initially denied it

was him in the photograph. While searching the premises, officers found a scale and

plastic baggies, items commonly associated with packaging marijuana. In Mr. Ruiz­

Alcala's bedroom, officers found a small bag of seeds and marijuana. The seeds were

later identified as marijuana seeds. Outside the house, officers found twine and tarp of

the same color as that seen at the grow campsite, as well as another bag of seeds.

Forensic examination of these seeds showed they were not marijuana seeds. A drug

sniffing dog alerted on several vehicles parked at the search address. The dog was

trained to alert on the odor of marijuana, cocaine, methamphetamine, and heroin.

The State charged Mr. Ruiz-Alcala with manufacture of a controlled substance,

marijuana. At trial, without objection by defense counsel, the State introduced the

twine, tarp, scales, plastic baggies, both bags of seeds, and testimony describing the

No. 30944-4-111 State v. Ruiz-Alcala

behavior of the drug sniffing dog. In his cross-examination of Detective Robert Tucker,

defense counsel showed tarps, twine, and plastic bags are common household items.

Defense counsel's cross-examination of Deputy Jesus Rojas, the dog's handler,

revealed the dog could not differentiate between drugs nor was there a way to tell how

much time had elapsed since any drugs had been present.

In Mr. Ruiz-Alcala's testimony, he said he played volleyball with the two men he

was seen picking up at the drop site. The men told Mr. Ruiz-Alcala they were going

camping and asked him to pick them up the following night. While he had never been to

the drop site, he had previously driven in that area. When he arrived to pick up the

men, Mr. Ruiz-Alcala said the men did not smell and he did not question their lack of

camping gear. In response to a question by defense counsel, Mr. Ruiz-Alcala said he

knew nothing about the gun found in his brother's room.

The jury found Mr. Ruiz-Alcala guilty as charged. After a hearing where the trial

court questioned the relevance of the marijuana seeds and the drug sniffing dog's

alerts, defense counsel filed a brief memorandum requesting a new trial as a result of

ineffective assistance of counsel. The trial court granted Mr. Ruiz-Alcala a new trial,

finding the result of the trial would have been different had defense counsel sought to

exclude the small baggie containing marijuana seeds, the conduct of the dog, and the

tarp. The court found defense counsel's mention of the gun to be prejudicial error. The

State appealed.

ANALYSIS

The issue is whether the trial court abused its discretion under CrR 7.5(a)(8) in

granting Mr. Ruiz-Alcala a new trial based on finding Mr. Ruiz-Alcala received

ineffective assistance of counsel. The State contends defense counsel engaged in

strategic or tactical conduct and Mr. Ruiz-Alcala fails to show prejudice.

A trial court may grant a new trial when "substantial justice has not been done."

CrR 7.5(a)(8). Unless constituting a manifest abuse of discretion, decisions granting or

denying a new trial are not disturbed. State v. Dawkins, 71 Wn. App. 902, 906, 863

P.2d 124 (1993). However, stronger evidence of an "abuse of discretion is required to

set aside an order granting a new trial than one denying it." Id. at 907. "An abuse of

discretion exists unless it can realistically be said that no reasonable person would take

the position adopted by the trial court." Id. (internal quotations omitted). When

reviewing the grant of a new trial based on a finding of ineffective assistance of counsel,

we apply the abuse of discretion standard. Id.

The Sixth Amendment of the United States Constitution guarantees a criminal

defendant the right to effective assistance of counsel. Strickland v. Washington, 466

U.S. 668, 686,104 S. Ct. 2052,80 L. Ed. 2d 674 (1984). To establish ineffective

assistance of counsel, a defendant must prove (1) defense counsel's representation

was deficient, i.e., it was below an objective standard of reasonableness under the

circumstances and (2) the deficient representation prejudiced him, i.e., a reasonable

probability exists the outcome would have been different without the deficient

representation. State v. McFarland, 127 Wn.2d 322, 334-35, 899 P.2d 1251 (1995).

We must strongly presume effective representation. Id. at 335. Ineffective assistance

of counsel claims cannot be based on defense counsel's legitimate strategic or tactical

decisions. Id. at 335-36.

Washington courts recognize U[c]ounsel's decisions regarding whether and when

to object fall firmly within the category of strategic or tactical decisions." State v.

Johnston, 143 Wn. App. 1, 19, 177 P.3d 1127 (2007). Failing to object constitutes

ineffective assistance of counsel U[o]nly in egregious circumstances, on testimony

central to the State's case." Id. Thus, to prove ineffective assistance of counsel for

failing to object, a defendant must "show that the failure to object fell below prevailing

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State v. Dawkins
863 P.2d 124 (Court of Appeals of Washington, 1993)
State v. McFarland
899 P.2d 1251 (Washington Supreme Court, 1995)
State v. Sexsmith
157 P.3d 901 (Court of Appeals of Washington, 2007)
State v. Sexsmith
138 Wash. App. 497 (Court of Appeals of Washington, 2007)
State v. Johnston
177 P.3d 1127 (Court of Appeals of Washington, 2007)

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