State of Washington v. Michael Adrian Harness

CourtCourt of Appeals of Washington
DecidedDecember 4, 2018
Docket35481-4
StatusUnpublished

This text of State of Washington v. Michael Adrian Harness (State of Washington v. Michael Adrian Harness) 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. Michael Adrian Harness, (Wash. Ct. App. 2018).

Opinion

FILED DECEMBER 4, 2018 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STATE OF WASHINGTON, ) ) No. 35481-4-III Respondent, ) ) v. ) ) MICHAEL HARNESS, ) UNPUBLISHED OPINION ) Appellant. )

KORSMO, J. — Michael Harness appeals from his sentences for vehicular assault

and hit and run—bodily injury, arguing that the two offenses should have been

considered same criminal conduct. The trial court did not err when it determined that

they were not the same criminal conduct.

FACTS

The relevant facts can be stated succinctly. Driving a borrowed Ford Explorer,

Mr. Harness drove through a stop sign at high speed and struck a Toyota Corolla driven

by Ms. Tamara Fischer. Ms. Fischer suffered numerous serious injuries, including

traumatic brain injury.1 Mr. Harness fled the scene on foot, but was captured later.

1 Other injuries included broken ribs, collapsed lungs, a broken pelvis, a broken sacrum, bruising of the heart, a ruptured diaphragm, a ruptured spleen, and lacerations of the stomach and intestines. No. 35481-4-III State v. Harness

Ultimately, the prosecutor filed charges of hit and run, bodily injury (count I),

vehicular assault by driving in a reckless manner (count II), and vehicular assault by

driving with disregard for the safety of others (count III). Ms. Fischer was the victim of

both vehicular assault counts. The jury found Mr. Harness guilty on all three counts.

After merging the two vehicular assault convictions, the trial court found that the

two remaining crimes did not constitute the same criminal conduct and that the offender

score was “9+.” Clerk’s Papers (CP) at 105-106. The court imposed concurrent top end

sentences of 84 months on each count.

Mr. Harness appealed to this court. A panel considered his appeal without hearing

argument.

ANALYSIS

This appeal argues, on two different bases, that the court erred in treating the two

offenses as separate criminal conduct. The trial court did not abuse its discretion.

At issue is RCW 9.94A.589(1)(a). When imposing sentence under that

subsection, courts are required to include each other current offense in the offender score

unless one or more of those offenses constitute the same criminal conduct, in which case

they shall be “counted as one crime.” The statute then defines that particular exception to

the scoring rule: “‘Same criminal conduct,’ as used in this subsection, means two or

more crimes that require the same criminal intent, are committed at the same time and

place, and involve the same victim.” Id.

2 No. 35481-4-III State v. Harness

Offenses have the same criminal intent when, viewed objectively, the intent does

not change from one offense to the next. State v. Dunaway, 109 Wn.2d 207, 215, 743

P.2d 1237 (1987). “Intent, in this context, is not the particular mens rea element of the

particular crime, but rather is the offender’s objective criminal purpose in committing the

crime.” State v. Adame, 56 Wn. App. 803, 811, 785 P.2d 1144 (1990). Courts have also

looked at whether one crime furthers the other or whether the offenses were part of a

recognized plan or scheme. Dunaway, 109 Wn.2d at 215 (furtherance test); State v.

Lewis, 115 Wn.2d 294, 302, 797 P.2d 1141 (1990) (same scheme or plan).

It is the defendant’s burden to establish that offenses constitute the same criminal

conduct. State v. Graciano, 176 Wn.2d 531, 540-541, 295 P.3d 219 (2013). We review

the trial court’s ruling on this issue for abuse of discretion. Id. at 541. Discretion is

abused when it is exercised on untenable grounds or for untenable reasons. State ex rel

Carroll v. Junker, 79 Wn.2d 12, 26, 482 P.2d 775 (1971).

The record establishes, and the parties agreed at sentencing, that Mr. Harness had

8.5 points of criminal history. The other current offense served to move the sentence

range to the “9+” category.2 Thus, a same criminal conduct finding would have served to

reduce the standard range for each offense.

2 Both charges are classified as “felony traffic offenses” under RCW 9.94A.030(26)(a). In accordance with RCW 9.94A.525(11), the vehicular assault conviction adds two points to the standard range for the hit and run, while the latter offense only adds one point to the range for the vehicular assault conviction. As a result,

3 No. 35481-4-III State v. Harness

As an initial matter, Mr. Harness’s failure to argue in the trial court that the two

offenses were the same criminal conduct waived the issue. Graciano, 176 Wn.2d at 541.

Anticipating this problem, Mr. Harness claims his attorney provided ineffective

assistance by failing to make this argument at sentencing. To prevail on such a claim, he

would have to show both that his attorney erred so significantly that he failed to live up to

the standards of the profession and that counsel’s error prejudiced him. Strickland v.

Washington, 466 U.S. 668, 688-692, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984); State v.

McFarland, 127 Wn.2d 322, 334-335, 899 P.2d 1251 (1995). Even assuming that it was

error to not raise the matter, the record does not establish prejudice. In order to prevail,

the record would need to show that the court likely would have granted the request. See

McFarland, 127 Wn.2d at 333-334 (any error in failing to request suppression hearing

was not manifest because defendants could not show that trial court would have granted

the motion).

Given the trial court’s remarks about the severe injuries the defendant randomly

had inflicted on Ms. Fischer and the imposition of a top end sentence, there is no reason

to believe that the trial court would have exercised its decision in favor of Mr. Harness if

he had asked to do so. More importantly, the two offenses do not appear to have

constituted the same criminal conduct. First, the two offenses occurred sequentially, thus

Mr. Harness’s exact offender score would be 10.5 for the hit and run and 9.5 for the vehicular assault.

4 No. 35481-4-III State v. Harness

negating the possibility that they occurred at the same time. Second, the objective intent

of the two offenses was not the same. The intent of the vehicular assault was merely poor

driving—driving in a reckless manner and/or in disregard of the safety of others. In

contrast, the objective intent in the hit and run was an effort to avoid responsibility for the

consequences of his driving.

The two offenses did not share the same intent. They also did not further each

other. Although there would have been no need to flee except for the accident, the

assault was not committed to further the escape. These two sequential offenses did not

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
State Ex Rel. Carroll v. Junker
482 P.2d 775 (Washington Supreme Court, 1971)
State v. Adame
785 P.2d 1144 (Court of Appeals of Washington, 1990)
State v. Lewis
797 P.2d 1141 (Washington Supreme Court, 1990)
State v. McFarland
899 P.2d 1251 (Washington Supreme Court, 1995)
State v. Flake
883 P.2d 341 (Court of Appeals of Washington, 1994)
State v. Dunaway
743 P.2d 1237 (Washington Supreme Court, 1988)
State v. Ramirez
426 P.3d 714 (Washington Supreme Court, 2018)
State v. Graciano
295 P.3d 219 (Washington Supreme Court, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
State of Washington v. Michael Adrian Harness, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-michael-adrian-harness-washctapp-2018.