State v. Trotter

Court of Appeals of Kansas·Decided August 25, 2017·No. 114743·Unpublished

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 114,743

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS,

Appellee,

v.

ERIC L. TROTTER,

Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; JEFFREY E. GOERING, judge. Opinion filed August 25, 2017. Affirmed.

Korey A. Kaul, of Kansas Appellate Defender Office, for appellant.

Julie A. Koon, assistant district attorney, Marc Bennett, district attorney, and Derek Schmidt, attorney general, for appellee.

Before POWELL, P.J., ATCHESON, J., and FAIRCHILD, S.J.

PER CURIAM: A jury sitting in Sedgwick County District Court found Defendant Eric L. Trotter guilty of criminal possession of a firearm by a convicted felon. He has appealed on two grounds: The district court improperly admitted a brief security video showing him carrying what appears to be a rifle; and the district court instructed the jurors in a way that impermissibly diminished the possibility they would ignore the law and the evidence to find him not guilty. We find no error in those respects and affirm.

FACTUAL AND PROCEDURAL HISTORY

Wichita police responded to a "shots fired" call for help from an apartment complex in August 2014 and as part of their investigation reviewed a videotape from a security camera in the lobby of the building. The video showed Trotter and others running through the lobby and out of the building. Trotter carried what looked to be an assault rifle.

About a week later, detectives interviewed another person shown in the video who identified Trotter. Officers then found Trotter, and a detective interviewed him at the police station. Trotter told the detective he had driven to the apartment building with several other people, including a man he knew by the nickname "G." According to Trotter, G grabbed a rifle from the trunk of the car and went into the building. Trotter said he followed and took the rifle from G in the interests of maintaining the peace. Trotter told the detective that while they were in the building, they heard gunshots so they ran outside. Trotter said he carried the gun with him and later threw it away in a grassy area. The gun was never found. Trotter told the detective he didn't fire the rifle.

Everybody agrees that in August 2014 Trotter had been convicted of a predicate felony that would make his possession of a firearm unlawful under K.S.A. 2014 Supp. 21-6304. The State charged Trotter with one count of violating K.S.A. 2014 Supp. 21- 6304(a)(3)(B), a severity level 8 nonperson felony.

The jury convicted Trotter as charged in a 2-day trial in June 2015. The district court later sentenced Trotter to serve 17 months in prison and placed him on postrelease supervision for 12 months. Trotter has filed a timely appeal.

LEGAL ANALYSIS

Video Clip as Evidence

As we have indicated, Trotter contends the district court erred in admitting about 4 seconds of the videotape showing him running through the apartment lobby with the rifle. The district court denied Trotter's pretrial motion to exclude the videotape but limited what could be admitted to the brief excerpt. Trotter renewed his objection at trial on the grounds of relevance and undue prejudice, and the district court allowed him a continuing objection to the video clip and the testimony about it. From our perspective, Trotter has properly preserved his objection for appellate review.

On appeal, Trotter contends the video clip was unfairly prejudicial because his quick exit from the building improperly suggested to the jury that he had been involved in a crime and was making a getaway. He says the district court could just as easily have admitted several still images captured from the video—providing the jurors the same relevant information without an impermissibly prejudicial overlay fostered by his running through the lobby.

As a starting point, we recognize that relevant evidence generally should be considered admissible evidence. K.S.A. 60-407(f); State v. Huddleston, 298 Kan. 941, 959, 318 P.3d 140 (2014). Here, the relevance of the images on the videotape is undisputed, since the clip shows someone who looks to be Trotter in possession of something that looks to be a rifle. That's highly relevant to a charge of unlawful possession of a firearm. But, as Trotter points out, even relevant evidence may be excluded in certain circumstances. If the probative value of the evidence "is substantially outweighed by" its undue prejudice, the district court has the authority to exclude the evidence. 298 Kan. at 961-62. A district court's ruling weighing probative value against undue prejudice will be reviewed on appeal for abuse of judicial discretion. State v. Wilson, 295 Kan. 605, Syl. ¶ 1, 289 P.3d 1082 (2012). A district court exceeds that

discretion if it rules in a way no reasonable judicial officer would under the circumstances, if it ignores controlling facts or relies on unproven factual representations, or if it acts outside the legal framework appropriate to the issue. See Northern Natural Gas Co. v. ONEOK Field Services Co., 296 Kan. 906, 935, 296 P.3d 1106, cert. denied 134 S. Ct. 162 (2013); State v. Ward, 292 Kan. 541, Syl. ¶ 3, 256 P.3d 801 (2011), cert. denied 565 U.S. 1221 (2012).

Here, we see no abuse of that broad discretion. The district court grasped the material facts about the videotape and Trotter's reasons for wanting to exclude it as evidence. And the district court understood the applicable law. We cannot say the ruling admitting a short portion of the videotape was so far afield no other district court would have ruled that way.

As we have said, the video provided highly probative evidence bearing directly on the elements of the charged crime. Conversely, the ostensible prejudice stemmed from an oblique implication Trotter sought to impute to the video. The implication was contrary to Trotter's explanation for why he was running—an explanation the jurors heard through the statement he made to the detective, which was also admitted as evidence. On balance, any unfair prejudice could not be said to substantially outweigh the probative value of the video clip. Although use of still photos captured from the video might have been a preferable alternative, the district court's choice did not come close to an abuse of discretion.

Even if we were mistaken in that assessment, however, any error in admitting the video clip would have been harmless. Trotter effectively confessed to the elements of the crime when he told the detective he took a rifle from G and then carried it around for a substantial period of time. That established Trotter possessed a firearm. And K.S.A. 2014 Supp. 21-6304 grants no dispensation to someone who retains possession of a firearm to prevent its misuse or for some other purportedly benign purpose. During the trial, Trotter

did not attempt to deny what he said to the detective. Rather, his lawyer argued that nobody, including Trotter, knew for sure whether the gun was, in fact, a firearm—it might have been a BB gun, a toy, or a replica. The jury apparently was unimpressed by that idea. As to the remaining element of the charge, Trotter stipulated that he been convicted of an unidentified predicate crime bringing him within the prohibition in K.S.A. 2014 Supp. 21-6304. The jurors were so instructed. In short, the case against Trotter was compelling even without the video clip. See State v. Orange, No. 108,806, 2014 WL 37688, at *5 (Kan. App. 2014) (unpublished opinion) ("A defendant's confession may be uniquely damning evidence in front of a jury, for it inculpates the defendant from his or her own mouth."). The admission of the video clip, if erroneous, was not the catalyst for the guilty verdict. See State v. McCullough, 293 Kan. 970, 983, 270 P.3d 1142 (2012) (A nonconstitutional error may be declared harmless if "there is no reasonable probability that such error affected the outcome of the trial in light of the entire record.").

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