State of West Virginia v. Gary Richard Baker

CourtWest Virginia Supreme Court
DecidedFebruary 21, 2013
Docket11-0915
StatusSeparate

This text of State of West Virginia v. Gary Richard Baker (State of West Virginia v. Gary Richard Baker) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of West Virginia v. Gary Richard Baker, (W. Va. 2013).

Opinion

No. 11-0915 - State of West Virginia v. Gary Richard Baker

FILED February 21, 2013 released at 3:00 p.m. RORY L. PERRY II, CLERK SUPREME COURT OF APPEALS LOUGHRY, Justice, dissenting: OF WEST VIRGINIA

I dissent from the majority’s decision in this case for two reasons. First, I

believe the evidence regarding the petitioner’s incarceration and parole status was properly

admitted into evidence by the trial court for the limited purpose of explaining the passage of

time. Secondly, assuming arguendo that the evidence was improperly admitted, I believe it

was harmless error. As set forth below, there was sufficient evidence from which the jury

could have reached a verdict of guilt beyond a reasonable doubt absent the arguably

inadmissible evidence.

A. The Petitioner Opened the Door

I strongly disagree with the majority’s conclusion that the petitioner did not

open the door through his cross-examination of Mr. Smith for the admission of evidence

regarding his prior incarceration and parole status. The majority reached its decision by

focusing on a narrow passage of the cross-examination and turning a blind eye to the rest of

16 the testimony elicited by the petitioner from Mr. Smith.1 The petitioner questioned Mr.

Smith as follows:

Q Mr. Smith, I’m not going to keep you very long. [The petitioner] wasn’t the first employee that you had to let go, was he?

A Oh, no, sir.

Q. You must have dealt with a lot of them.
A. Quite a bit.
Q. Probably wasn’t one of the first ones agitated about it, either?
A. I would assume not so.
Q. When did you sell the Fairlea Subway?
A. January of 2000.
Q. So you haven’t owned it for nine years?
A. That’s correct.

....

Q. And summer of ‘99, is when the confrontation between you and [the petitioner] took place?

A. That’s when the incident occurred, yes.

1 Obviously, I believe that the State should not have confessed error in this case. Regardless, as even the majority acknowledges, this Court will not allow a confession of error to dictate the outcome of a case. Syl. Pt. 8, State v. Julius, 185 W.Va. 422, 408 S.E.2d 1 (1991).

Q. 10 years ago, this past summer?
Q. And this was a part time job?
A. Yes, it was.
Q. With no benefits?
A. No benefits.
Q. Minimum wage, I’m sure?
A. That’s correct, to start.
Q. And he was only there for a week?
A. Week to 10 days.
Q. So it’s not like he lost his pipeline to the gold mine, right?
A. I don’t know what his opinion was.
Q. Again, you’re paying minimum wage, hiring part time without benefits, correct?

The State’s theory at trial was that the petitioner robbed the Subway for

revenge against Mr. Smith because he had been fired. When the petitioner’s cross

examination of Mr. Smith is considered in its entirety, it is obvious that an impartial juror

could not help but wonder why a person that only worked at this Subway for a week making

minimum wage with no benefits would wait ten years to exact his revenge for being fired.

It is clear that through the cross-examination of Mr. Smith, the petitioner successfully called

into question the State’s revenge motive. Because of the court’s pre-trial ruling that evidence

regarding the petitioner’s incarceration for the past ten years and status as a parolee was not

admissible, the State was left unable to explain the ten-year lapse of time. Like the trial

court, I believe that at this point in the proceedings, the evidence of the petitioner’s

incarceration and parole became more probative than prejudicial and became admissible to

explain the time gap pursuant to the doctrine of opening the door.

Just as a defendant has a right to a fair trial, so does the State. The defense has

to comply with the established rules of procedure and evidence in the same manner as the

prosecution. That was not done here. This was a classic case of opening the door. The

petitioner successfully excluded inadmissible evidence from the prosecution’s case and then

elicited other evidence to his own advantage which the State could not put in proper context.

In such instance, “the doctrine of opening the door allows a party to explore [the] otherwise

inadmissible evidence . . . [because] the opposing party has made unfair prejudicial use of

related evidence.” United States v. Lum, 466 F.Supp. 328, 334 (D. Del. 1979). Here, it

would have been grossly unfair to allow the jury to believe that nothing occurred in the past

ten years that would have prevented the petitioner from exacting his revenge sooner.

I also think it is important to note that the trial court limited the information

given to the jury concerning the petitioner’s prior ten-year incarceration and parole status.

In that regard, the jury was not informed of the nature of the crimes that resulted in the

petitioner’s incarceration. Moreover, the trial court gave four limiting instructions,

cautioning the jury that the information was to be used for the limited purpose of explaining

the passage of time.2 The trial court clearly took the necessary steps to ensure the jury

2 The trial court gave the following limiting instruction to the jury before the petitioner’s parole officer testified:

Before the State begins to examine this witness, I am required to give you what is called a limiting instruction.

There will be some evidence admitted during Ms. Fitzgerald’s testimony that you may consider only for a limited purpose. So I’m going to read that instruction now.

The Court instructs the members of the jury that evidence of collateral acts of misconduct is not to be considered in establishing guilt of the crime with which the defendant is charged, and you may consider that evidence for a very limited purpose, only. You may not consider it as proof of the charges contained in the indictment. You may consider it to show the passage of time.

You may not use this evidence in consideration of whether the State has established the crime charged in the indictment. In addition, such evidence is not relevant to any other matters, such as the character of the defendant, whether the defendant is a bad person, or whether the defendant had the propensity or the disposition to commit the crime charged. This evidence may not be considered in that regard, since the defendant’s character is not an issue.

understood the limited purpose for which the evidence of the petitioner’s prior incarceration

and parole was being offered. Therefore, unlike the majority, I find no error in the trial

court’s admission of this evidence pursuant to the doctrine of opening the door.

B. Clearly Harmless Error

Assuming arguendo that the evidence of petitioner’s incarceration and parole

status should have been excluded, I believe that the admission of that evidence was harmless

error in this case. Contrary to the “grave doubts” expressed by the majority, I believe that

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Related

State v. Julius
408 S.E.2d 1 (West Virginia Supreme Court, 1991)
State v. Guthrie
461 S.E.2d 163 (West Virginia Supreme Court, 1995)
United States v. Lum
466 F. Supp. 328 (D. Delaware, 1979)

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State of West Virginia v. Gary Richard Baker, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-west-virginia-v-gary-richard-baker-wva-2013.