State v. Jilka

CourtCourt of Appeals of Kansas
DecidedApril 14, 2017
Docket115274
StatusUnpublished

This text of State v. Jilka (State v. Jilka) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Jilka, (kanctapp 2017).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 115,274

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

THOMAS J. JILKA, Appellant.

MEMORANDUM OPINION

Appeal from Miami District Court; AMY L. HARTH, judge. Opinion filed April 14, 2017. Affirmed.

Kai Tate Mann, of Kansas Appellate Defender Office, for appellant.

Amanda G. Voth, assistant solicitor general, and Derek Schmidt, attorney general, for appellee.

Before ARNOLD-BURGER, C.J., ATCHESON and BRUNS, JJ.

Per Curiam: Thomas J. Jilka was charged with two counts of felony animal cruelty after he admitted to abusing a dog. At trial, Jilka argued that he could only be convicted of the lesser included offense, misdemeanor animal cruelty, because he did not act maliciously; rather, he argued the effects of methamphetamine withdrawal caused him to act out. The jury found Jilka guilty of both felony counts. He now appeals. Finding no reversible error, we affirm Jilka's convictions.

1 FACTUAL AND PROCEDURAL HISTORY

Shortly after moving in with his sister and her boyfriend, Jilka, Timothy McCarley came home from work and noticed that his dog, Baxter, had a number of injuries on his head that looked like they had been made with a Phillips head screwdriver. Because McCarley suspected that someone was hurting his dog, he purchased a camera to record what happened in his room, where the dog was kept, while he was gone. Approximately 2 weeks after McCarley noticed the first injuries, he came home and noticed 30 to 40 new injuries on Baxter's head.

When McCarley reviewed his camera feed, he discovered that Jilka spent time in his room that day. On the video, which was played for the jury during Jilka's trial, Jilka can be seen entering and exiting the room several times over a 41-minute period. The first time Jilka entered the room, he had with him a large beer bottle and a cigarette. He left almost immediately and returned with a screwdriver. Shortly after his return to the room, off screen sounds of banging and yelping began. Banging, thudding, and slamming noises mixed with sounds of a dog barking, whimpering, yelping, and panting continue off and on for about 15 minutes. Jilka's voice can then be heard taunting Baxter—asking the dog if he's "scared," telling him "that's what you get," and threatening to "hit you in your fucking face." A while later, Jilka can again be heard telling the dog "that's what you get."

Approximately 30 minutes after he began, Jilka left the room and turned off the light. The room was quiet for several minutes, the only sound being the panting of a dog. Jilka, however, returned to the room and again taunted the dog, calling him a "defenseless little bitch." At that time, more banging and slamming noises can be heard. Shortly thereafter, Jilka left the room for the last time.

2 After watching the video, McCarley went to his mother, Wendy McCarley, told her what Jilka had done, and asked her to call the police. Police came and McCarley turned over a copy of the video footage to them.

The next day, Detective David Stuteville located Jilka at his parents' house and conducted an interview about the incident. When Stuteville made contact with Jilka, he asked if Jilka knew why he was there to see him. Jilka replied that he believed the detective was there to talk to him about the "abuse of the dog." During the course of the interview, Stuteville asked Jilka why he had abused the dog. Jilka replied that "the dog was obnoxious and he didn't like the dog." Jilka admitted that he had abused the dog on two separate occasions a couple weeks apart. Jilka said that during the first incident, he punched the dog and stuck him with a screwdriver several times. During the second incident, he again struck the dog with a screwdriver, hit him, jabbed him with a broom handle, punched him, and choked him. When asked if he had intended to kill Baxter, Jilka replied that he had not, he "'just [wanted] to inflict pain.'"

At the time of the interview, Jilka appeared calm and did not seem to be under the influence of drugs or alcohol. Stuteville asked Jilka if he had been under the influence when he abused Baxter. Jilka contended that he had not been intoxicated at all.

Jilka was charged with two counts of felony animal cruelty. At trial, Jilka's theory of defense was not that he was entirely innocent, but rather that he was guilty only of the lesser included charge. Jilka argued that the effects of methamphetamine withdrawal caused him to act out against Baxter so that his actions were not done maliciously.

The jury found Jilka guilty on both counts of felony animal cruelty. Jilka now appeals.

3 ANALYSIS

The district court did not err when it denied Jilka's motion for a mistrial.

Jilka first argues that the district court erred when it denied his motion for mistrial after the State, during voir dire, referenced the fact that Jilka was charged with a felony crime. Jilka argues that this violated the State's own motion in limine which was granted and prohibited the parties from "refer[ring] to, or mak[ing] mention of, the possible sentence the defendant will face should he be found guilty of the crimes[s] charged."

When a motion for mistrial is made, the district court conducts a two-step analysis. First, it determines if, as a result of the alleged error, the "proceeding suffered some fundamental failure." State v. Corey, 304 Kan. 721, 730, 374 P.3d 654 (2016). If it answers that question in the affirmative, the district court goes on to consider "whether the trial can continue without an injustice, i.e., whether the prejudicial conduct's damaging effect can be removed or mitigated by an admonition, jury instruction, or other action. If not, the trial court must determine whether the degree of prejudice results in an injustice." 304 Kan. at 730. If the district court finds injustice, it declares a mistrial. 304 Kan. at 730.

On appeal, this court reviews each of the district court's determinations separately. First, this court examines the district court's conclusion regarding whether there was a fundamental failure and asks whether the conclusion was arbitrary, fanciful, or unreasonable; based on an error of law; or based on an error of fact. 304 Kan. at 730. If this court determines that the district court correctly found that there was a fundamental failure, it then reviews the entire record to determine whether the fundamental failure affected the trial's outcome, i.e., resulted in injustice. 304 Kan. at 731 (recognizing that in the past review of both parts has been described as abuse of discretion, but the second step is actually reviewed for harmlessness). If the error was not a constitutional error, this

4 court should only reverse the district court if there is a reasonable probability that the error affected the outcome of the trial. But a constitutional error may be declared harmless only when it is demonstrated beyond a reasonable doubt the error will not or did not affect the trial's outcome in light of the entire record, i.e., when there is no reasonable possibility the error contributed to the verdict. 304 Kan. at 731-32.

After the prosecutor mentioned to the potential jurors that Jilka had been charged with felony animal cruelty, a sidebar was held during which Jilka argued that mention of the severity of the charge violated the State's motion in limine. The district court denied Jilka's motion for mistrial but admonished the State not to mention the severity of the crime again.

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State v. Jilka, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-jilka-kanctapp-2017.