State of West Virginia v. Kevin Travis Costello

CourtWest Virginia Supreme Court
DecidedApril 2, 2021
Docket19-0326
StatusSeparate

This text of State of West Virginia v. Kevin Travis Costello (State of West Virginia v. Kevin Travis Costello) 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. Kevin Travis Costello, (W. Va. 2021).

Opinion

FILED April 2, 2021 No. 19-0326 – State v. Costello released at 3:00 p.m. EDYTHE NASH GAISER, CLERK SUPREME COURT OF APPEALS WOOTON, J., concurring, in part, and dissenting, in part: OF WEST VIRGINIA

While I concur with the majority’s general analysis of the recidivist issues, 1

I respectfully dissent to the majority’s refusal to address the obvious prejudice to petitioner

resulting from the State’s use of an undisclosed confession in obtaining the third and

recidivist-triggering offense. Hiding behind claims that this error was somehow

unpreserved below—and unwilling to undertake a plain error analysis notwithstanding our

clear authority to do so—the majority’s opinion leaves the somewhat breathtaking

conclusion that the State may use an undisclosed confession against a defendant, as long

as the government agent to whom it was made withholds its existence from the prosecutor.

In so doing, the majority implicitly sanctions and encourages non-disclosure of confessions

and elevates technicalities over the fundamental rights of petitioner.

Petitioner was charged with DUI causing serious bodily injury upon

allegations that he used heroin while driving, causing him to crash and seriously injure a

young boy. At trial, petitioner’s defense was that the crash was purely accidental and that

he ingested heroin after the accident to dispose of it. Since petitioner was on probation at

1 I concur in the majority’s analysis of the sufficiency of the recidivist evidence introduced and its conclusion that the character of the underlying offenses is an issue of law. I likewise concur in its conclusion that the nature of the underlying offenses satisfies the requirements of State v. Hoyle, 242 W. Va. 599, 836 S.E.2d 817 (2019). However, given my position that petitioner’s conviction of the triggering third offense was erroneous, I would likewise set aside the recidivist conviction and remand for a new trial on the final offense. 1 the time, he met with his probation officer after the accident. In its required pretrial

disclosures, the State disclosed documents generated during the meeting including a

document wherein petitioner admitted “us[ing] drugs to wit: Heroin” and “manifest[ing]

behavior that threatened the safety of yourself or others, or that could result in your

imprisonment; which caused you to be charged with DUI (narcotics) with felony serious

bodily harm.” Petitioner moved to suppress these written admissions and the trial court

agreed that the second statement—admitting to behavior that “threatened [] safety” or

“could result in [] imprisonment”—was inadmissible because it was phrased disjunctively

and therefore ran afoul of West Virginia Rule of Evidence 403.

At no time did the State disclose the existence of any oral confession to

petitioner’s probation officer. In fact, the State represented that despite meeting with the

probation officer on four separate occasions to discuss his testimony, he never mentioned

a confession. However, at trial, the probation officer—in an admitted surprise to the State,

defense counsel, and the court—testified that petitioner confessed to using heroin prior to

the accident:

Said he was driving from work. I guess the heroin was called elephant or something to that effect. He was driving from work. He said he snorted the heroin. He remembers crossing the bridge. After he crossed the bridge, he said he blacked out. When he came to, the vehicle had turned over and that’s when the accident happened. 2

2 The probation officer reiterated and confirmed the critical aspect of this confession—that petitioner used heroin before the accident—on cross and again on redirect: (continued . . .) 2 (footnote added). At the close of the probation officer’s testimony, petitioner’s counsel

requested a sidebar and objected specifically to this testimony, moving for a mistrial as a

result. The court stated that “I was not aware at the pretrial conference that this witness

would make this statement as admission of what the defendant said[.]” Regardless, the

court denied the motion for mistrial because it found that the confession did not fall within

the ambit of its order excluding the written admission. Petitioner’s counsel then renewed

his motion for a mistrial at the close of the State’s case, again, based on this surprise alleged

confession. 3 Following the verdict, petitioner’s counsel yet again orally moved for a new

trial on the basis of this undisclosed confession.

Petitioner then filed a timely motion for a new trial where he again argued

that the undisclosed confession fell within the scope of the written admission that was

excluded by the court and otherwise surprised and prejudiced petitioner’s defense. The

State responded that the confession testified to by the probation officer was offered much

Q. And he admitted to you that he snorted heroin before he crossed the bridge into West Virginia?

A. And blacked out afterwards, correct. 3 During both of these oral motions, counsel made clear that he objected to the admission of this statement but attempted to bootstrap the statement to the previously excluded written admission from the probation documents. Counsel later explained that he framed his initial objection in this manner was because he believed the court’s ruling to include “any oral statements which would have been associated with that admission.” However, the court disagreed that the statement fell within the contemplation of its order excluding the written statement, particularly given that no one knew about the confession at the time of the court’s order. 3 “[t]o the State’s surprise” and that it could “only speculate why [the probation officer] did

not share this information.” The State nevertheless maintained that the confession was

clearly voluntary and was not excluded by the court’s prior order regarding the written

admission.

Importantly, during the hearing on petitioner’s motion for a new trial, the

parties and the court unmistakably focused exclusively on the State’s failure to disclose

this confession, the State’s culpability in that failure, and the effect of petitioner’s attempt

to explain that confession during his case-in-chief. Petitioner’s counsel argued “if the state

didn’t know about it, then that is a negligent failure to disclose discovery by the state

because they should have interviewed their witness and had enough information to know

what he was going to testify to.” (Emphasis added). Counsel explained that his client was

“depriv[ed] [] of material information” and explored the devastating impact of a

“professional, you know, licensed, bonded state actor saying that they had received a full

confession” on petitioner’s defense. Counsel maintained that the probation officer’s failure

to advise the State of the alleged confession only to offer it unsolicited at trial was

“misconduct by a state actor . . . . who intentionally suppressed a highly material statement”

and that “[j]ust because [the prosecutor wasn’t] . . . suppressing the information doesn’t

mean the state didn’t suppress the information.” Counsel stated that “[e]verything might

4 have changed regarding trial strategy if I had known that . . . we had an actual confession

given to a state actor. That changes everything, Your Honor.” 4

In response, the prosecutor conceded that the State “is required to disclose to

the defendant a summary of any oral statement made to an agent of the state and the state

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State of West Virginia v. Kevin Travis Costello, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-west-virginia-v-kevin-travis-costello-wva-2021.