State of Washington v. Stephen A. Taylor

CourtCourt of Appeals of Washington
DecidedMay 20, 2025
Docket59042-5
StatusUnpublished

This text of State of Washington v. Stephen A. Taylor (State of Washington v. Stephen A. Taylor) 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. Stephen A. Taylor, (Wash. Ct. App. 2025).

Opinion

Filed Washington State Court of Appeals Division Two

May 20, 2025

IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON

DIVISION II STATE OF WASHINGTON, No. 59042-5-II

Respondent,

v.

STEPHEN AARON TAYLOR, UNPUBLISHED OPINION

Petitioner.

CRUSER, C.J.—Stephen Aaron Taylor shoved his wife into a wall, breaking her nose. The

State initially charged Taylor with fourth degree assault in district court. Taylor pleaded not guilty.

The State then charged Taylor with second degree assault in superior court and moved to dismiss

the fourth degree assault charge. Taylor opposed the motion and also moved to withdraw his plea

of not guilty to the fourth degree assault charge. The district court allowed Taylor to withdraw his

not guilty plea and then plead guilty to fourth degree assault, because the State knew about X-rays

showing that Taylor had broken his wife’s nose before the district court arraignment but did not

disclose those X-rays to Taylor.

The State appealed the order letting Taylor withdraw his not guilty plea and implicitly

denying the State’s motion to dismiss to superior court. The superior court reversed the district

court, thereby vacating Taylor’s guilty plea. After the superior court made its oral ruling, Taylor

moved to dismiss the RALJ appeal for lack of jurisdiction. The superior court denied this motion No. 59042-5-II

because it did not believe there was a mechanism for it to hear the motion after making its oral

ruling.

Taylor appeals. He argues that the superior court did not have jurisdiction to hear the RALJ

appeal and erred by not addressing the motion to dismiss the appeal, and that we should reverse

the superior court. We affirm.

FACTS

I. BACKGROUND AND DISTRICT COURT PROCEEDINGS

During an argument, Taylor shoved his wife, causing her to fall face-first into a wall. One

of the couple’s children called the police. When an officer arrived, Taylor’s wife, who is a nurse,

stated that she believed her nose was broken. Taylor’s wife “stated that she would get an X-Ray

done at work tomorrow” and release her medical records to police. Clerk’s Paper’s (CP) at 13.

The State charged Taylor with fourth degree assault, a gross misdemeanor, in district court.

The above information was included in the probable cause statement attached to the citation.

At an initial hearing, the district court found probable cause to charge Taylor with fourth

degree assault and entered conditions of release including a no-contact order prohibiting Taylor

from contacting or approaching his wife.

Several days later, after securing counsel, Taylor pleaded not guilty to fourth degree

assault. That same day, the State charged Taylor with second degree assault, a felony, in superior

court. The State then moved to dismiss the district court charge without prejudice under CrRLJ

8.3(a). At a hearing, the State explained that it initially charged Taylor with fourth degree assault

because it did not have his wife’s medical records, then decided to charge him with second degree

assault after an X-ray confirmed that his wife’s nose was broken. The prosecutor asserted, “the

2 No. 59042-5-II

dismissal is well within my prosecutorial discretion.” 1 Verbatim Rep. of Proc. (VPR) at 19. The

State also filed an order terminating the pretrial no-contact order alongside the motion to dismiss.

Taylor opposed the motion to dismiss and simultaneously moved to withdraw his not guilty

plea, asking the district court to allow him to plead guilty to the fourth degree assault. Taylor

argued that the State had an obligation to disclose the records showing that Taylor had broken his

wife’s nose, and that he could not have knowingly, intelligently, and voluntarily pleaded not guilty

to fourth degree assault without knowing that he risked being charged for second degree assault if

he did so. In opposition to this motion, the State explained that it held off on dismissing the fourth

degree assault charge until the second degree assault charges were filed to avoid prematurely

terminating the pretrial no-contact order. “And I think that is a proper exercise of my discretion to

maintain that no-contact order, maintain the protection of the victim in this case.” Id. at 34.

The district court orally granted Taylor’s motion to withdraw his not guilty plea, implicitly

denying the State’s motion to dismiss. The district court found that because the State had evidence

to support a charge for second degree assault and was “actively planning to purse a felony charge,”

it had an obligation to disclose the evidence to Taylor and his counsel pre-arraignment and

withheld this evidence in bad faith. Id. at 40. As a remedy for this discovery violation, the district

court stated that it would allow Taylor to withdraw his plea of not guilty and set a new arraignment

for him to plead guilty.

The State moved for reconsideration, arguing that the district court’s decision violated the

separation of powers because the State did not offer an inappropriate reason for the motion to

dismiss. The State also filed another motion to dismiss, this time “with prejudice because the

Superior Court’s authority supersedes this Court’s.” Id. at 44. At a hearing, the State explained

3 No. 59042-5-II

that it knew the X-ray existed before Taylor’s district court arraignment, but did not acquire the

X-ray until later. The State argued that the only information it withheld from Taylor was the

prosecutor’s decision to charge him with second degree assault if he did not plead guilty to the

fourth degree assault. Taylor responded that the State’s actions bordered on vindictive prosecution

because the State told the victim that Taylor “could have entered a guilty plea or could have taken

full responsibility at the time of arraignment; he didn’t. And two and a half hours later they file[d]

felony charges.” Id. at 52.

The district court denied reconsideration. In a written ruling granting Taylor’s motion, the

district court concluded that “[t]he State has an ongoing duty to disclose evidence under the

discovery rules and that duty applies regardless of when the State itself receives the evidence.” CP

at 54. The district court also concluded that “[a] defendant has a right to enter a not guilty plea at

arraignment. However, such a plea must be made knowingly, intelligently, and voluntarily. The

defendant’s plea of not guilty in this case was based in part on the State’s withholding of evidence

from the defendant and his counsel.” Id. The order stated that the remedy was that Taylor “must

be allowed to withdraw his original plea of not guilty and be allowed the opportunity to enter a

plea of guilty.” Id.

The district court then allowed Taylor to plead guilty to fourth degree assault over the

State’s objection. The district court imposed a sentence of 364 days with 363 days suspended and

gave Taylor credit for time served for one day.

II. RALJ APPEAL

The State filed a notice of appeal to superior court for the district court’s “rulings regarding

denying the State’s motion to [d]ismiss without prejudice.” Id. at 137. In its brief, the State asserted

4 No. 59042-5-II

that it was appealing the district court’s decision which “ultimately allowed the defendant to plead

guilty as charged.” Id. at 97. The State emphasized the district court’s ruling “that the defendant

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