State Of Washington, V. Ryan Toth

CourtCourt of Appeals of Washington
DecidedJune 18, 2024
Docket58338-1
StatusUnpublished

This text of State Of Washington, V. Ryan Toth (State Of Washington, V. Ryan Toth) 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. Ryan Toth, (Wash. Ct. App. 2024).

Opinion

Filed Washington State Court of Appeals Division Two

June 18, 2024

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 58338-1-II

Respondent,

v.

RYAN THOMAS TOTH, UNPUBLISHED OPINION

Appellant.

GLASGOW, J.—Ryan Toth was convicted of residential burglary for breaking into his

estranged wife’s house while a protection order prohibited him from entering her home.

Toth appeals, arguing that insufficient circumstantial evidence supports his conviction and

that the victim penalty assessment and DNA collection fee should be stricken from his judgment

and sentence. In a statement of additional grounds, he argues that he was deprived of the right to

counsel during a pretrial hearing and that there were instances of judicial bias and prosecutorial

misconduct in his pretrial proceedings and trial.

We remand for the trial court to strike the victim penalty assessment and DNA collection

fee. We otherwise affirm.

FACTS

I. BACKGROUND

Toth and Elizabeth Bramlett married in 2019 and they have a child in common. At the time

of the burglary, Toth and Bramlett were separated and in the middle of dissolution proceedings. 58338-1-II

During the proceedings, the court granted a protection order that prohibited Toth from contacting

Bramlett.

Bramlett lived in a home she co-owned with Toth, but Bramlett obtained a second

protection order that prevented Toth from being at or near the home. After the second protection

order, Toth moved out, taking some of his personal items and leaving others behind in the home.

About two months after the second protection order was entered, Bramlett returned to her

residence after a weekend trip away. She noticed that the garage door would not open and the

electric keypad for the front door was broken. Once inside, Bramlett noticed several other things

had changed since the last time she was home. For example, a pair of Toth’s shoes was missing

from the home and a different pair of Toth’s shoes was now present in the laundry room. Two

important documents had also been moved. The first document concerned a phone that the

Washington State Department of Children, Youth, and Families (DCYF) provided to Bramlett.

The second document was from the Oregon Department of Human Services (DHS) and concerned

renewing state benefits.

Bramlett called 911 to report a break-in, alleging that Toth was responsible. The State

investigated and ultimately charged Toth with residential burglary, malicious mischief in the third

degree, and several other crimes.

II. PRETRIAL HEARINGS

The trial court held a pretrial hearing to consider the State’s motions in limine, which

consisted predominantly of motions to exclude evidence. The prosecutor and defense counsel were

present in court for the hearing, while Toth joined via Zoom. Toth told the trial court that the audio

of the proceeding was a bit quiet for him, but Toth was able to hear and respond to questions from

2 58338-1-II

the court and defense counsel throughout. At one point during the hearing, Toth got disconnected

from Zoom, but he soon rejoined the hearing via speakerphone. While Toth was reconnecting to

the hearing, the trial court confirmed which exhibits were admissible to show Toth’s activities

during some of the time the burglary could have taken place and excluded some text messages

between Toth and Bramlett’s mother.

The trial court made several pretrial rulings regarding the admissibility of evidence. For

example, Toth sought admission of evidence about law enforcement’s consideration of charges

against Bramlett. Although defense counsel argued that this information would provide context to

the reasonable fear element of the stalking charge, the trial court ultimately excluded evidence of

law enforcement’s consideration of charges against Bramlett because this evidence was not

relevant. However, the trial court reasoned that some of the factual descriptions of surrounding

events could still be admissible to show whether reasonable fear existed or not.

Later in the pretrial hearing, the trial court evaluated the admissibility of statements from

Bramlett’s mother and whether Bramlett’s mother could serve as a witness for the defense.

Although defense counsel argued that Bramlett’s mother had unique insight into Bramlett’s

reputation for dishonesty, the trial court ultimately excluded Bramlett’s mother as a witness

because she was being offered to impermissibly “comment on the credibility of other witnesses”

in violation of ER 608(b). 1 Verbatim Rep. of Proc. (VRP) at 36.

Finally, the trial court considered the admissibility of photos that provided some examples

of what Toth was doing during the weekend the burglary took place. Defense counsel argued that

while such evidence was not enough to assert an alibi defense, the photos showed that Toth really

was with his child for parts of the weekend. The trial court ruled that most of the photos were

3 58338-1-II

admissible to show what the defendant was doing during the time period in which the burglary

occurred.

III. TRIAL

A. State Witnesses

Bramlett began by testifying that before the burglary occurred, there was another incident

where her security camera recorded someone putting nails in and around her car. Bramlett alleged

that Toth was the person in the video based on her familiarity with his walk, his clothes, and his

build. Toth was ultimately found not guilty of malicious mischief, the charge related to these

allegations.

As for the burglary, Bramlett testified that she arrived back at her residence after a weekend

away. Upon her arrival, she noticed that the garage door would not open electronically. Then she

tried opening the front door and realized that the electric keypad was broken and the manual key

required more force than usual to open the door. Once inside, Bramlett said that she noticed a

variety of disturbances in her home, including a vacuum cleaner wedged into the garage door, the

air conditioning unit moved from the window to the floor, and a trap with a lawn mower blade set

up near the garage door.

Bramlett also testified that a pair of Toth’s work boots were missing, while a different pair

of Toth’s shoes that had not been there before were found in the laundry room. Additionally,

Bramlett said that two important documents that she usually kept on the counter in the middle of

the home had been moved. The first document concerned a phone provided to her by DCYF. The

second document, from DHS, was about renewing state benefits. Bramlett testified that the first

4 58338-1-II

document was hand delivered to her by a DCYF employee handling her case. The second

document was delivered to Bramlett’s post office box.

Bramlett testified that when she received this second document, Toth had no access to the

post office box, because Bramlett had removed authorization for Toth to access the mailbox and

changed the keys. Bramlett also testified that she received both of these documents after the second

protection order against Toth was issued, which prohibited Toth from entering or coming near

Bramlett’s home.

Furthermore, a DCYF employee who handled Bramlett and Toth’s case testified that on

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