State v. Kichinko

613 P.2d 792, 26 Wash. App. 304, 1980 Wash. App. LEXIS 2100
CourtCourt of Appeals of Washington
DecidedJune 2, 1980
Docket7012-6-I
StatusPublished
Cited by11 cases

This text of 613 P.2d 792 (State v. Kichinko) 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. Kichinko, 613 P.2d 792, 26 Wash. App. 304, 1980 Wash. App. LEXIS 2100 (Wash. Ct. App. 1980).

Opinion

Callow, C.J.

—Andrew Michael Kichinko appeals the judgment and sentence entered upon a jury conviction of attempted possession of stolen property in the first degree.

Officers of the Seattle Police Department began an investigation into Kichinko's activities on October 4, 1977, *306 based upon information that he was fencing stolen property. As a part of this investigation, an undercover officer sold 33 purportedly stolen items to Kichinko prior to April 18, 1978. Their approximate retail value was $1,109, and the officer received $376 from Kichinko in exchange for the purportedly stolen property.

On April 5, 1978, the officers had purchased a coin collection for $2,000. Thereafter, Kichinko was asked by the undercover officer whether he was interested in stolen coins. Kichinko indicated that he was. The officer was given permission to apply for an order authorizing the interception and recording of oral communication and a video recording. He applied for and received this order from a judge of the King County Superior Court on April 17, 1978. The officer arranged a purchase of the coins at Kichinko's place of business on April 19, 1978, after an April 18 meeting was canceled. Wired for sound and followed by a van containing recording and video tape equipment, the officer went to Kichinko's office. They held conversations in both the office and the officer's unmarked car. The coin collection was shown to and handled by Kichinko. After the conversation ended, Kichinko was arrested for attempted possession of stolen property in the first degree. The conversation was recorded and videotaped.

At the pretrial motion to suppress, the State and the defense agreed that the officer would be unable to testify from personal knowledge as to the exact nature of the conversation between himself and Kichinko. The recording and video tape were admitted into evidence over Kichinko's objection, and the State and the defendant agreed that without the recording prosecution was not possible. The material portions of the application and the order authorizing the interception and recording of the conversation are attached as an appendix hereto.

The following issues are presented: (1) What criteria must be satisfied before a judge may lawfully issue an order authorizing the police to record and videotape a conversation between a suspect and an undercover officer? (2) Was *307 there probable cause to believe a crime had been or was about to be committed by the suspect?

We turn to the first inquiry concerning the criteria which must be satisfied before a judge may issue an order authorizing the recording and videotaping of a conversation between a suspect and an undercover officer.

Kichinko contends the order cannot lawfully issue without a showing that normal investigative procedures had failed, or were unlikely to succeed or were too dangerous, citing RCW 9.73 and United States v. Kalustian, 529 F.2d 585 (9th Cir. 1975). He contends that the statutes authorizing electronic eavesdropping must be strictly construed, that their plain language imposes this requirement, and that such language cannot be modified by construction, citing United States v. Giordano, 416 U.S. 505, 40 L. Ed. 2d 341, 94 S. Ct. 1820 (1974); Purse Seine Vessel Owners Ass'n v. Moos, 88 Wn.2d 799, 567 P.2d 205 (1977).

The State argues that the act does not require the judge to conclude that other procedures had failed, would fail or were too dangerous before police may be allowed to record conversations. RCW 9.73.090(2); RCW 9.73.130(3)(f). The State argues, alternatively, that if this so-called "necessity" requirement is subject to judicial review, it should be read to require only a showing of "reasonable necessity" to render it consistent with the purpose of the act and to make it effective. Amburn v. Daly, 81 Wn.2d 241, 501 P.2d 178 (1972).

Prior to 1977, RCW 9.73.030 made it unlawful for a political subdivision of the state to record a private communication between two or more individuals without first obtaining the consent of all participants. Former RCW 9.73.030; Laws of 1967, 1st Ex. Sess., ch. 93, § 1. A violation of this statute rendered the recording inadmissible in a criminal case except when the crime jeopardized national security. RCW 9.73.050. 1 Although the law allowed and continues to allow court ordered recordings pursuant to *308 RCW 9.73.040, such recordings are not admissible in a criminal case unless the crime jeopardizes national security. RCW 9.73.050. We read these sections of the statute as pertaining specifically to matters involving danger to human life, arson, riot or national security. We interpret the requirement of RCW 9.73.040(l)(c), requiring the application to set forth a statement that there are "no other *309 means readily available for obtaining such information," as applying only to those felonies mentioned in that section of the statute and not to felonies not specified therein.

In 1977, the legislature added a new exception to RCW 9.73.090 which allowed broader evidentiary use of recordings obtained pursuant to court authorization. Laws of 1977, 1st Ex. Sess., ch. 363, § 3. 2 The legislature also added RCW 9.73.130 which listed the required contents of each application for such authorization. 3

*310 The State argues that RCW 9.73.130(3)(f) is designed to insure recordings will not be unsupervised or routinely employed.

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Bluebook (online)
613 P.2d 792, 26 Wash. App. 304, 1980 Wash. App. LEXIS 2100, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kichinko-washctapp-1980.