State v. Anderson

509 P.2d 80, 8 Wash. App. 782, 1973 Wash. App. LEXIS 1506
CourtCourt of Appeals of Washington
DecidedApril 16, 1973
Docket1425-1
StatusPublished
Cited by7 cases

This text of 509 P.2d 80 (State v. Anderson) 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 v. Anderson, 509 P.2d 80, 8 Wash. App. 782, 1973 Wash. App. LEXIS 1506 (Wash. Ct. App. 1973).

Opinion

James, J.

By jury trial Don Raymond Anderson was convicted of first-degree murder. He pleaded insanity pursuant to RCW 10.76.010.

On appeal Anderson first contends that, in defining criminal insanity for the jury, the trial judge should have instructed in terms of the so-called “Durham” as opposed to the “M’Naghten” rule. He further asserts that, in any event, the instruction given “erroneously articulated and applied the M’Naghten rule.” In State v. Thomas, 8 Wn. App. 495, 507 P.2d 153 (1973), we pointed out that the Washington Supreme Court has consistently adhered to its interpretation of the M’Naghten rule and has consistently rejected the Durham and other “irresistible impulse” definitions of criminal insanity. In State v. Ferrick, 81 Wn.2d 942, 506 P.2d 860 (1973), the Washington Supreme Court again reiterated its commitment to its version of M’Naghten. The instruction given was a correct definition of criminal insanity in Washington.

Anderson next claims that he was denied his constitutional right to trial by an' impartial jury. The record discloses that, pursuant to RCW 10.49.050, three veniremen, who would under no circumstances impose the death penalty, were excused upon the state’s challenge for cause. Anderson argues that after Furman v. Georgia, 408 U.S. 238, 33 L. Ed. 2d 346, 92 S. Ct. 2726 (1972), which declared the death penalty as imposed in recent years to be unconstitutional, the state can no longer 'have a valid interest in excluding jurors who will under no circumstances impose the death penalty.

Anderson was tried in 1971, before the Furman decision, and Washington law then permitted the death penalty in *784 first-degree murder cases. RCW 10.49.050 entitled the state to challenge for cause any veniremen who could under no circumstances impose a sentence authorized by law. State v. Canaday, 79 Wn.2d 647, 488 P.2d 1064 (1971). In language fully applicable to this case, the court in State v. Ferrick, supra, noted at page 945 that: “It is sufficient that at the time the instant case was tried, the statutes in question required the jury to determine whether the death penalty should be imposed.”

Finally, Anderson claims error in the denial of his motion to suppress the opinion testimony of a psychiatrist called by the state in rebuttal of Anderson’s insanity defense. The relevant circumstances are as follows: Anderson was arrested shortly before noon, 3 days after the homicide. He was immediately advised of his constitutional rights by one of the arresting officers. The prosecution, anticipating an insanity defense and concerned with Anderson’s competency to stand trial, arranged for a psychiatric interview which took place in the city jail in the late afternoon of the day of the arrest. The murder charge was filed 7 days later.

During the course of the interview, an attorney appeared at the jail and asked to see Anderson. The attorney was required to wait until the psychiatrist had completed his interview bef ore he was permitted to see Anderson.

The trial judge conducted a fact finding hearing in the absence of the jury before ruling on Anderson’s motion to suppress the psychiatrist’s testimony. The trial judge found that at the time of his appearance at the city jail, the attorney had not yet been retained or appointed to represent Anderson; that the prosecution was not advised that Anderson had counsel when the psychiatric interview was arranged; that at one point during the psychiatric interview, the attorney, who was a former prosecutor and who was acquainted with the psychiatrist, opened the door of the interviewing room and asked how much longer the interview would last, and that at no time did the attorney expressly indicate to jail personnel, the psychiatrist or the *785 prosecution, that he wanted the psychiatric interview to be terminated.

The trial judge further found that the psychiatrist fully advised Anderson of 'his constitutional right to remain silent and his right to have legal counsel; that not only did Anderson indicate that he understood his rights, but in fact he exercised them by refusing to answer questions concerning his acquaintance with the victim and questions concerning the commission of the crime.

Anderson contends that the custodial interrogation by the psychiatrist was in violation of his right to the “assistance of counsel for his defense” at a critical stage of the prosecution, guaranteed him by the United States Constitution’s Sixth Amendment. Anderson urges that the landmark cases of Miranda v. Arizona, 384 U.S. 436, 16 L. Ed. 2d 694, 86 S. Ct. 1602, 10 A.L.R.3d 974 (1966), and Escobedo v. Illinois, 378 U.S. 478, 12 L. Ed. 2d 977, 84 S. Ct. 1758 (1964) require that the state’s violation of this fundamental constitutional right be judicially condemned, as in Gilbert v. California, 388 U.S. 263, 273, 18 L. Ed. 2d 1178, 87 S. Ct. 1951 (1967) by “a per se exclusionary” ruling suppressing the testimony of the psychiatrist.

The state’s response to Anderson’s contention is fourfold. The state first cites Kirby v. Illinois, 406 U.S. 682, 32 L. Ed. 2d 411, 92 S. Ct. 1877 (1972) as authority for the assertion that an accused’s constitutional right to counsel does not attach until “the initiation of adversary judicial criminal proceedings — whether by way of formal charge, preliminary hearing, indictment, information, or arraignment.” Kirby v. Illinois, supra at 689. Second, citing Lee v. County Court, 27 N.Y.2d 432, 318 N.Y.S.2d 705, 267 N.E.2d 452 (1971), the state contends that by entering a plea of criminal insanity, Anderson necessarily waived his Fifth and Sixth Amendment rights insofar as they were applicable to a psychiatric examination. Third, the state urges that the statements which Anderson made to the psychiatrist were “verbal acts” analogous to physical evidence and therefore not affected by Fifth and Sixth Amendment rights. Cf. *786 United States v. Baird, 414 F.2d 700 (2d Cir. 1969); State v.

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Bluebook (online)
509 P.2d 80, 8 Wash. App. 782, 1973 Wash. App. LEXIS 1506, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-anderson-washctapp-1973.