State Of Washington v. Phillip Linch Schloredt

CourtCourt of Appeals of Washington
DecidedDecember 24, 2018
Docket77013-6
StatusUnpublished

This text of State Of Washington v. Phillip Linch Schloredt (State Of Washington v. Phillip Linch Schloredt) 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. Phillip Linch Schloredt, (Wash. Ct. App. 2018).

Opinion

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON STATE OF WASHINGTON, ) c-1 ) No. 77013-6-1 1"-a Respondent, ) co . 7414 4 ) DIVISION ONE rn cl-ri v. ) ) UNPUBLISHED OPINION 1••5 7 ,-tl.f : •c" v-iorri cf,rn CI PHILLIP LINCH SCHLOREDT, ) Ts' Z•7> ) -..-t--- .,,, Appellant. ) FILED: December 24, 2018 as

BECKER, J.—Appellant Phillip Schloredt lit a container full of gasoline and

threw it in the direction of a police officer. The officer's car and several nearby

vehicles were set aflame. A jury convicted Schloredt of first degree arson. He

appeals his conviction on a number of grounds, including that the trial court

improperly excluded layperson testimony regarding Schloredt's mental illness.

We affirm.

FACTS

The alleged arson occurred on September 21, 2015. Seattle Police

Officers John Paquette and James Norton responded to a 9-1-1 call at the home

where appellant Phillip Schloredt lived with his mother. The call was from

Schloredt's mother. She said that her son, 56 years old at the time of trial, had a

history of mental illness and was declaring that he was going to kill himself. She

requested that someone come to her house to take Schloredt to a hospital. No. 77013-6-1/ 2

When the officers arrived at the scene, Schloredt's gray truck was parked

in the middle of the street along with other vehicles that were blocking traffic.

Schloredt was dragging a container full of gasoline towards his truck. Officer

Paquette testified that when he got out of his police car, he saw flames shoot up

and the container landed in the bed of the pickup truck with the flaming liquid

splashing onto the hood of the patrol car. The flames engulfed the truck, Officer

Paquette's car, and several other cars parked on the street. The officers' dash-

cam video, which captured the dramatic scene, was shown to the jury at trial.

Using their fire extinguishers, and aided by a neighbor with a garden hose, the

officers were able to extinguish the blaze. In the chaos, Schloredt ran away. A

short time later, officers found him hiding not far away in a blackberry thicket and

arrested him.

The State charged Schloredt with arson in the first degree, RCW

9A.48.020(1)(a). This charge required the State to prove that Schloredt

"knowingly and maliciously" caused a fire or explosion which was "manifestly

dangerous to any human life, including firefighters." RCW 9A.48.020(1)(a).

Before trial, Schloredt moved to be found incompetent. Schloredt was

evaluated and diagnosed with an unspecified schizophrenia spectrum and other

disorders. At the time, Schloredt was taking antipsychotic medication and an

antidepressant. The evaluator concluded that Schloredt was competent to stand

trial and the trial court agreed.

2 No. 77013-6-1/ 3

Schloredt's defense was a general denial. He did not assert a defense of

diminished capacity and he did not plan to present expert testimony regarding his

mental state.

The trial in March 2017 lasted four days. The jury deliberated for two

hours before convicting Schloredt as charged. His sentence of 108 months was

within the standard range.

ANALYSIS

Rebutting Proof of Malice

Schloredt contends the trial court improperly excluded key evidence

offered to rebut the State's proof of malice.

The term "malice" imports "an evil intent, wish, or design to vex, annoy, or

injure another person. Malice may be inferred from an act done in willful

disregard of the rights of another, or an act wrongfully done without just cause or

excuse, or an act or omission of duty betraying a willful disregard of social duty."

RCW 9A.04.110(12). The dash-cam video was the primary evidence the State

relied on to prove malice. The jury also heard the recording of a call Schloredt

made from jail on the night of the fire to his friend, Louie Gaddini. In the call,

Schloredt began by asking,"Was that awesome or what?" When Gaddini

suggested that Schloredt would be charged with arson, Schloredt answered that

he would also be charged with assaulting a police officer. Gaddini told Schloredt

that he burned a police car, to which Schloredt responded, "Did I? Sweet. That's

good."

3 No. 77013-6-1/4

To rebut the evidence of malice, Schloredt wished to present testimony by

his mother and sister that he was mentally ill and that he had not been taking his

prescribed medications at the time of the incident. The State successfully moved

in limine to exclude such evidence as irrelevant because Schloredt was not

asserting a diminished capacity defense.

A diminished capacity defense "allows a defendant to undermine a

specific element of the offense, a culpable mental state, by showing that a given

mental disorder had a specific effect by which his ability to entertain that mental

state was diminished." State v. Clark, 187 Wn.2d 641, 650, 389 P.3d 462 (2017).

Clark, a decision issued only a few weeks before Schloredt's trial, was the

principal authority considered by the trial court on the State's motion to exclude.

Clark holds that expert opinion testimony will not be admitted to prove what is

functionally a diminished capacity defense unless that defense is affirmatively

pleaded.

The defendant in Clark had killed the victim with a single gunshot to the

head. Charged with premeditated murder, he claimed the shooting was an

accident. Thus, as in the present case, the primary disputed issue was the

defendant's level of intent. Clark, 187 Wn.2d at 645. Although Clark did not

assert diminished capacity as a defense, he sought to present an expert witness

who would testify that he scored at the very bottom in standardized intelligence

tests. The trial court excluded the expert testimony as irrelevant and confusing to

the jury. The court did, however, rule that the defendant could elicit relevant

observation testimony by lay witnesses concerning his intellectual deficits,

4 No. 77013-6-1/ 5

including that he had been enrolled in special education, received Social Security

disability benefits and was generally considered as "slow" by people who knew

him. Clark, 187 Wn.2d at 646.

On appeal, the Supreme Court approved the trial court's ruling. It was

clear the purpose for offering the expert's testimony was to establish diminished

capacity, Le., that Clark's intellectual deficits "impaired his ability to understand

and assess the risks of his behavior, thereby reducing the likelihood that Clark

acted with a culpable mental state" when he shot the victim. Clark, 187 Wn.2d at

651.

We do not question the principle that a criminal defendant has the constitutional right to present evidence in his or her own defense, and relevant observation testimony tending to rebut any element of the State's case, including mens rea, is generally admissible. However, expert opinion testimony that a defendant has a mental disorder that impaired the defendant's ability to form a culpable mental state is, by definition, evidence of diminished capacity.

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Related

Clark v. Arizona
548 U.S. 735 (Supreme Court, 2006)
State v. Hernandez
997 P.2d 923 (Court of Appeals of Washington, 1999)
State v. Hickman
954 P.2d 900 (Washington Supreme Court, 1998)
State v. Powell
893 P.2d 615 (Washington Supreme Court, 1995)
State v. Lough
889 P.2d 487 (Washington Supreme Court, 1995)
State v. Cronin
14 P.3d 752 (Washington Supreme Court, 2000)
State Of Washington v. Ronald Dale Wafford
397 P.3d 926 (Court of Appeals of Washington, 2017)
State v. Hickman
135 Wash. 2d 97 (Washington Supreme Court, 1998)
State v. Cronin
142 Wash. 2d 568 (Washington Supreme Court, 2000)
State v. Clark
389 P.3d 462 (Washington Supreme Court, 2017)
State v. Hernandez
997 P.2d 923 (Court of Appeals of Washington, 1999)

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State Of Washington v. Phillip Linch Schloredt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-v-phillip-linch-schloredt-washctapp-2018.