State Of Washington, V. Joseph C. Gioiosa

CourtCourt of Appeals of Washington
DecidedFebruary 10, 2026
Docket59093-0
StatusUnpublished

This text of State Of Washington, V. Joseph C. Gioiosa (State Of Washington, V. Joseph C. Gioiosa) 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. Joseph C. Gioiosa, (Wash. Ct. App. 2026).

Opinion

Filed Washington State Court of Appeals Division Two

February 10, 2026

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 59093-0-II

Respondent,

v.

JOSEPH CARL GIOIOSA, UNPUBLISHED OPINION

Appellant.

CRUSER, C.J.—Joseph Gioiosa appeals his convictions for first degree murder, first degree

attempted murder, first degree assault, drive-by shooting, and unlawful possession of a firearm or,

in the alternative, his sentence. Gioiosa argues that (1) the jury instruction on accomplice liability

was constitutionally deficient, (2) the trial court abused its discretion by denying his request for

expert services, (3) the trial court erred by including Gioiosa’s juvenile convictions in his offender

score, and (4) Gioiosa is entitled to resentencing because the trial court failed to recognize its

discretion to run the sentences for Gioiosa’s multiple serious violent offenses concurrently as an

exceptional sentence.

We conclude that (1) the challenged jury instruction correctly stated the law on accomplice

liability, (2) the trial court did not abuse its discretion by denying Gioiosa’s request for expert

services because Gioiosa never made such a request, (3) the trial court correctly included Gioiosa’s

juvenile convictions in his offender score in accordance with the law in effect at the time of the

offenses, and (4) Gioiosa is not entitled to resentencing because this error, if any, was invited and No. 59093-0-II

not preserved for review, and the record does not show that the trial court was unaware of its

discretion to run Gioiosa’s serious violent offense sentences concurrently by declaring an

exceptional sentence downward.

FACTS

In the early hours of September 28, 2020, Joseph Gioiosa and Justin Coleman went to a

party to shoot rival gang member Trevon Richard. Coleman had recently been attacked by Richard

and members of his gang. When Coleman and Gioiosa arrived, Richard was standing outside of a

vehicle occupied by Damoni Nelson and Charles Hickman, high school students, unaffiliated with

a gang. A bullet, shot from inside Gioiosa and Coleman’s vehicle, went through the front

windshield and killed Nelson. The State charged Gioiosa with first degree murder, second degree

murder, attempted first degree murder, first degree assault, drive-by shooting, and unlawful

possession of a firearm. Coleman pleaded guilty to second degree murder with a firearm

enhancement. Gioiosa’s case proceeded to trial on a theory of accomplice liability.

During pretrial proceedings, the trial court granted Gioiosa’s request to represent himself.

The trial court granted Gioiosa a two-month continuance to prepare for trial. At the next status

hearing, Gioiosa requested a 90-day continuance while he waited for the Department of Assigned

Counsel (DAC) to respond to his request for a ballistics expert. Gioiosa explained:

So I’ve requested a ballistics expert since I was made aware of the State’s claim that I was the shooter in this case from September 28, 2020. I’ve written -- I’ve written a letter to DAC and also to Your Honor, but the letter to you, [your honor], was sent back to me because I didn’t follow the correct format. But I still haven’t heard anything back from DAC yet about this expert, which I think is crucial for my defense in this case. . . .

So I was just asking for 90 days to kind of get everything together and hopefully get this expert from DAC.

2 No. 59093-0-II

8 Verbatim Rep. of Proc. (VRP) at 364.

The trial court continued the trial one week, rather than 90 days. The trial court explained

that it was declining to grant a lengthier continuance because it had already continued the trial for

two months so that Gioiosa could prepare. The trial court also expressed its view that

[t]he issue of the ballistics expert, . . . that has been known for a while . . . I’m not sure that that is as crucial as Mr. Gioiosa may think in determining which side of the vehicle the shots were fired from. So I’m not inclined to continue this for a lengthy period of time to allow that to be explored any further.

Id. at 368-69.

The trial court later reappointed counsel at Gioiosa’s request.

At trial, defense counsel objected to the use of the Washington Pattern Jury Instruction on

accomplice liability. The jury instruction read:

A person is guilty of a crime if it is committed by the conduct of another person for which he or she is legally accountable. A person is legally accountable for the conduct of another person when he or she is an accomplice of such other person in the commission of the crime.

A person is an accomplice in the commission of a crime if, with knowledge that it will promote or facilitate the commission of the crime, he or she either:

....

(2) aids or agrees to aid another person in planning or committing the crime.

The word “aid” means all assistance whether given by words, acts, encouragement, support, or presence. A person who is present at the scene and ready to assist by his or her presence is aiding in the commission of the crime. However, more than mere presence and knowledge of the criminal activity of another must be shown to establish that a person present is an accomplice.

Clerk’s Papers (CP) at 293.

Defense counsel argued that the last two sentences of the instruction conflicted with each

other and that the second to last sentence incorrectly implied that a defendant can be held liable as

3 No. 59093-0-II

an accomplice based on mere presence and knowledge. The trial court overruled the objection,

explaining that the proposed instruction “mirrors the statutory language” and “appropriately

informs the jury that the State must prove more than the defendant was a knowing observer of a

crime. . . . You’ve got to be ready to assist.” 23 VRP at 1957-58.

The State referenced this jury instruction in closing, stating, “So a person can be merely

present and not do anything with knowledge of the crime that the principal’s doing--.” Id. at 1986.

Then defense counsel interjected with an objection. The trial court allowed the State to finish its

statement. The State then reiterated the language from the jury instruction that “ ‘more than mere

presence and knowledge of criminal activity of another must be shown to establish that a person

is an accomplice.’ ” Id. at 1987.

The jury convicted Gioiosa of first degree murder with a firearm enhancement, second

degree murder with a firearm enhancement, first degree attempted murder with a firearm

enhancement, and first degree assault with a firearm enhancement, drive-by shooting, and unlawful

possession of a firearm.

At sentencing, Gioiosa argued that his juvenile convictions should not be included in his

offender score because an amendment to RCW 9.94A.525, which went into effect after the

offenses but before sentencing, directs the court not to include such convictions. The State argued

that Gioiosa’s juvenile offenses should be included in his offender score because “the date of the

crime determines what law was in effect, and the date of the crime in this case by over two years

predates the statute that changed the prior juvenile offense issue.” 25 VRP at 2080. The trial court

referenced RCW 10.01.040

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