State Of Washington, V. Simeon Thomas Berkley

CourtCourt of Appeals of Washington
DecidedSeptember 6, 2022
Docket82588-7
StatusUnpublished

This text of State Of Washington, V. Simeon Thomas Berkley (State Of Washington, V. Simeon Thomas Berkley) 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.

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State Of Washington, V. Simeon Thomas Berkley, (Wash. Ct. App. 2022).

Opinion

THE COURT OF APPEALS FOR THE STATE OF WASHINGTON

STATE OF WASHINGTON, No. 82588-7-I

Respondent, DIVISION ONE

v. UNPUBLISHED OPINION

SIMEONE THOMAS BERKLEY,

Appellant.

ANDRUS, C.J. — Simeone Thomas Berkley appeals his conviction for

second degree murder, arguing that he shot Steven Whitemarsh in self-defense

during a road rage incident provoked by Whitemarsh. Berkley contends the trial

court erred in excluding evidence that Whitemarsh had previously engaged in

aggressive and alcohol-impaired driving, impairing his right to present a defense.

He also argues the prosecutor committed misconduct by characterizing his crime

as an “execution” and the trial court imposed mandatory legal financial obligations

(LFOs) that were unconstitutionally excessive. We reject these arguments and

affirm the judgment and sentence.

FACTS

On the evening of July 6, 2019, as Yuriy Gogun and his daughters drove

down Glenwood Avenue in Everett, they saw a car, driven by Simeone Berkley,

coming toward them. Gogun saw Berkley turn on his left turn signal and abruptly

Citations and pin cites are based on the Westlaw online version of the cited material. No. 82588-7-I/2

slow down. Gogun then saw the vehicle following Berkley, driven by Stephen

Whitemarsh, collide with the rear end of Berkley’s car.

Gogun pulled over and saw Berkley get out of his car and walk up to

Whitemarsh’s driver’s side window. Both Gogun and his daughter, Juliana,

testified they then saw Berkley pull out a gun and shoot Whitemarsh twice through

the window, pausing three to five seconds between the shots.

Beau Reeder, sitting in his car on Glenwood Avenue, heard a loud crash

behind him. When Reeder turned to look, he saw the collision. Reeder grabbed

his video camera and, as he got out of his car, heard two gunshots with a short

pause in between. Reeder began recording when he saw Berkley walking towards

him. Reeder asked him what happened and Berkley responded that the driver of

the following vehicle had been chasing him. Reeder then heard the engine of

Whitemarsh’s car revving loudly. Reeder and Berkley walked together to

Whitemarsh’s car. Reeder turned off his video camera while he attempted,

unsuccessfully, to remove Whitemarsh’s leg from the car’s accelerator. Berkley

reached into the car and took the keys out of the ignition. Reeder turned his video

camera back on when Berkley told him, “don’t worry about him. I shot him twice in

the head.” Reeder saw that Whitemarsh was bleeding and heard him moaning.

When police arrived, they found Whitemarsh still seated in his vehicle with

his seat belt fastened and his doors locked, with gunshot wounds to his face and

head. Whitemarsh died at the scene. The autopsy revealed that Berkley’s first

shot entered Whitemarsh’s lower lip and shattered his jawbone. The second shot

entered his skull behind his left ear. The Snohomish County chief medical

examiner testified that the shots were fired from a distance of 6 to 24 inches away. -2- No. 82588-7-I/3

Whitemarsh had a blood alcohol level of .195 and a THC level of 4.7 nanograms

per milliliter of blood.

The State charged Berkley with second degree murder. Berkley’s theory at

trial was that he shot Whitemarsh in self-defense.

Berkley testified that on the evening of the shooting, he was driving on

Glenwood Avenue to pick up dinner for himself and his wife. On the way, he

noticed Whitemarsh’s SUV closely following him. Berkley grew concerned about

what he described as Whitemarsh’s aggressive driving when, at a stop light,

Whitemarsh repeatedly revved his engine directly behind Berkley’s vehicle.

Berkley claimed he drove at an excessive rate of speed to get away from

Whitemarsh, but Whitemarsh continued to tailgate him. At some point, Berkley

decided he was “tired of the chase,” and slammed on his brakes, causing

Whitemarsh’s SUV to collide with the back of Berkley’s vehicle.

Berkley admitted he then got out of his car, walked over to Whitemarsh’s

driver’s side window, pulled a pistol from his pocket, and shot Whitemarsh twice.

He admitted he never saw a weapon and did not exchange any words with

Whitemarsh.

To support his theory of self-defense, Berkley sought to introduce three

pieces of evidence to demonstrate that Whitemarsh had previously engaged in

alcohol-fueled road rage incidents. First, he asked to introduce evidence that the

victim’s mother, Patricia Whitemarsh, told police that Whitemarsh “is a road rage

driver, that he gets angry at drivers, [and] that he carries a weapon in his car.”

Second, Berkley offered testimony from Alan Cunningham, who had observed

Whitemarsh aggressively tailgate another driver in the same manner as described -3- No. 82588-7-I/4

by Berkley. Third, Berkley sought to introduce Whitemarsh’s six prior convictions

for driving under the influence (DUI). Berkley argued that this evidence supported

his argument that Whitemarsh was the primary aggressor and that Berkley had a

reasonable apprehension of harm.

The trial court excluded the evidence under ER 404. The court reasoned

that Patricia Whitemarsh’s testimony was not “general and neutralized” to

constitute admissible reputation evidence and was instead inadmissible opinion

evidence. Cunningham’s testimony, the court held, was not general reputation

evidence, but was information about a single past incident, making it inadmissible

propensity evidence under ER 404(a) and inadmissible to establish a common

scheme or plan under ER 404(b). With regard to Whitemarsh’s DUI convictions,

the court held that they were inadmissible evidence of prior bad acts under ER

404(a), inadmissible propensity evidence under ER 404(b), and not probative of

whether Whitemarsh was the aggressor.

The jury found Berkley guilty of second degree murder and the court

sentenced him to 264 months of confinement.

ANALYSIS

Berkley’s Right to Present a Defense

Berkley first argues the trial court’s exclusion of the evidence of

Whitemarsh’s history of impaired and aggressive driving violated his right to

present a defense. We disagree.

In analyzing whether a trial court’s evidentiary decision violated a

defendant’s right to present a defense under the Sixth Amendment to the United

States Constitution, we first review the court’s evidentiary ruling for abuse of -4- No. 82588-7-I/5

discretion. State v. Jennings, 199 Wn.2d 53, 58, 502 P.3d 1255 (2022) (citing

State v. Arndt, 194 Wn.2d 784, 813, 453 P.3d 696 (2019)). A trial court abuses its

discretion if no reasonable person would take the view adopted by the trial court.

Jennings, 199 Wn.2d at 59. We then consider de novo whether the exclusion of

evidence violated the defendant’s constitutional right to present a defense. Id. at

58.

Berkley argues that the excluded evidence was admissible under either ER

404(a) or (b). We reject these arguments. Under ER 404(a), “[e]vidence of a

person’s character or a trait of character is not admissible for the purpose of

proving action in conformity therewith on a particular occasion.” ER 404(a)(2)

provides an exception to this rule for “[e]vidence of a pertinent trait of character of

the victim of the crime offered by an accused.” But even under this exception,

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