State of Washington v. Marvin Love Tate, Jr.

CourtCourt of Appeals of Washington
DecidedApril 24, 2025
Docket39668-1
StatusUnpublished

This text of State of Washington v. Marvin Love Tate, Jr. (State of Washington v. Marvin Love Tate, Jr.) 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. Marvin Love Tate, Jr., (Wash. Ct. App. 2025).

Opinion

FILED APRIL 24, 2025 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STATE OF WASHINGTON, ) No. 39668-1-III ) Respondent, ) ) v. ) UNPUBLISHED OPINION ) MARVIN LOVE TATE, JR., ) ) Appellant. )

JOHNSON, J.P.T. † — Marvin Love Tate Jr. was convicted by a jury of first degree

unlawful possession of a firearm, use of drug paraphernalia, and fourth degree assault

with domestic violence against an intimate partner. Mr. Tate appeals, making the

following claims of error: (1) his conviction for use of drug paraphernalia should be

reversed because the charge was brought outside the one-year statute of limitations,

(2) a photograph containing a red stain was admitted into evidence in error, (3) the State’s

witnesses repeatedly offered impermissible opinion testimony, (4) the prosecution

conducted misconduct by eliciting impermissible opinion testimony, expressing personal

beliefs on witness credibility during closing argument, and impugning defense counsel

during rebuttal closing argument, (5) ineffective assistance of counsel, (6) cumulative

† Brandon L. Johnson, an active judge of a court of general jurisdiction, is serving as a judge pro tempore of this court pursuant to RCW 2.06.150(1). No. 39668-1-III State v. Tate

error, and (7) the crime victim penalty assessment (VPA) should be removed from the

judgment and sentence. The State disagrees with Mr. Tate on the first six assignments

of error, but concedes the $500 VPA should be struck based on recent statutory changes.

We reverse and remand because (1) the use of drug paraphernalia charge was time

barred and broadened the original count of unlawful possession of a controlled substance,

and (2) impermissible opinion testimony, constituting manifest constitutional error, was

presented that may have introduced implicit racial bias to the jury. To assist the trial court

on remand, we address the evidentiary issue. While we accept the State’s concession to

strike the VPA, no further action is necessary on that obligation as Mr. Tate’s judgment

and sentence is reversed in its entirety. We decline to address Mr. Tate’s claims of

prosecutorial misconduct, ineffective assistance of counsel, and cumulative error as

unnecessary to resolving the appeal.

FACTS

On May 30, 2019, Marvin Love Tate Jr. was charged with first degree unlawful

possession of a firearm (UPF), unlawful possession of a controlled substance, and third

degree assault of a law enforcement officer. On May 5, 2021, the charges were amended

to add fourth degree assault with domestic violence against an intimate partner and use of

drug paraphernalia, and to remove the charge of unlawful possession of a controlled

2 No. 39668-1-III State v. Tate

substance. 1

On January 9, 2023, a jury found Mr. Tate guilty of UPF, use of drug

paraphernalia, and fourth degree assault with domestic violence against an intimate

partner. Mr. Tate was found not guilty of third degree assault of a law enforcement

officer.

Background

In the early morning hours of May 26, 2019, law enforcement responded to a

report of a large fight, involving 30 to 50 people, at the Towne Crier, a business in

Richland, Washington. 2 When officers arrived, no one was actively fighting but the

officers remained on scene to deter the crowd from fighting and to keep the peace.

Several officers noticed a “heated argument” between two individuals exiting the

establishment who were both “yelling at each other.” 1 Rep. of Proc. (RP) (Jan. 4, 2023)

at 415; see also 2 RP (Jan. 5, 2023) at 551; 2 RP (Jan. 6, 2023) at 735. One officer

believed that “an assault might occur between the parties” and approached them to

“break up [the] argument.” 1 RP (Jan. 4, 2023) at 416. The two individuals who were

1 On February 21, 2021, our Supreme Court, in State v. Blake, 197 Wn.2d 170, 481 P.3d 521 (2021), voided the statute criminalizing simple possession of a controlled substance on the basis that it violated constitutional due process. 2 This was the second response of officers that night to a disturbance at the Towne Crier.

3 No. 39668-1-III State v. Tate

arguing were later identified as Marvin Love Tate Jr. and Kathy Larson. 3 Mr. Tate is

a Black man and Ms. Larson is a White woman. The issue of a race was prevalent

throughout the underlying trial and remains so on review.

As one of the officers approached to break up the argument, he saw Mr. Tate point

two fingers at Ms. Larson and the officer believed he heard Mr. Tate say, “‘I should put

a gun to your head and basically end it.’” 1 RP (Jan. 4, 2023) at 416. The officer asked

Ms. Larson if he heard the statement correctly, to which she replied something along the

lines of “‘everything’s gonna be okay’” and “‘[i]t’s fine.’” Id. at 417. At the same time

the officer was speaking to Ms. Larson, Mr. Tate was “very highly agitated,” had “balled

up his fists,” and then took steps toward the officer while “yelling, screaming, swearing,”

and calling him “all sorts of names.” Id. The officer then left because he had not

witnessed a crime and there was no physical altercation, but first “advised Ms. Larson

that if she left with Mr. Tate, that [the officer] believed she would be assaulted by him.”

Id. At this point, Ms. Larson was neither disheveled nor exhibiting any signs that a

physical altercation had occurred. Similarly, Mr. Tate did not show any signs of injury

or that he had been involved in a physical altercation. Mr. Tate and Ms. Larson entered

3 Kathy Larson’s last name appears in the report of proceedings only as “Larson,” but in the clerk’s papers as both “Larson” and “Larsen.” We use “Larson” consistent with the trial proceedings.

4 No. 39668-1-III State v. Tate

a black Chrysler 300 sedan and left the Towne Crier together. One of Mr. Tate’s friends

was driving the vehicle. Mr. Tate was seated in the front passenger seat and Ms. Larson

in the rear passenger seat.

A few minutes later, dispatch reported an incident involving a black Chrysler 300

at a convenience store across the street from the Towne Crier. A witness, Robert

Fleming, called 911 to report a possible assault after a man got out of the front passenger

seat of the vehicle and leaned through the rear passenger-side window while screaming

and throwing punches at someone. The witness advised dispatch that he could also hear a

female screaming from the backseat of the vehicle. By the time officers arrived at the

convenience store, the vehicle was no longer there.

A short time later, an officer spotted the vehicle and performed a traffic stop.

Backup officers arrived and recognized the vehicle as the one they just saw at the Towne

Crier. Mr. Tate was in the front passenger seat, while Ms. Larson was in the rear

passenger seat, the same seats they occupied when they left the Towne Crier. Officers

noticed that Ms. Larson had red marks on her neck and chest area and her shirt was

stretched out and pulled over her shoulder, partially exposing her breast, which was not

consistent with her appearance minutes prior at the Towne Crier. An officer would later

testify that it was “obvious from appearance and the injuries on [Ms. Larson] that

something did take place.” 2 RP (Jan. 6, 2023) at 758.

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