State v. Watson

CourtCourt of Appeals of Kansas
DecidedMay 26, 2017
Docket114818
StatusUnpublished

This text of State v. Watson (State v. Watson) 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. Watson, (kanctapp 2017).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 114,818

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

BRIAN O'NEAL WATSON, Appellant.

MEMORANDUM OPINION

Appeal from Johnson District Court; TIMOTHY P. MCCARTHY, judge. Opinion filed May 26, 2017. Affirmed.

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

Shawn E. Minihan, assistant district attorney, Stephen M. Howe, district attorney, and Derek Schmidt, attorney general, for appellee.

Before STANDRIDGE, P.J., MCANANY, J., and HEBERT, S.J.

Per Curiam: Brian O'Neal Watson appeals from his conviction by a jury of attempted second-degree murder and level 4 aggravated battery. He argues he should have a new trial because: (1) he was excluded from the courtroom while the jury listened to the recording of his 911 call during their deliberations, and the prosecutor's trial assistant was allowed to play the recording for the jury; (2) jurors were observed dozing off and sleeping during his trial; (3) the prosecutor committed error in closing argument; (4) the trial court erroneously denied his requested instructions on lesser included offenses under the aggravated battery charge; (5) the trial court presented a clearly erroneous instruction to the jury; and (6) cumulative error deprived him of a fair trial. 1 We have examined each of these arguments and find no reversible error. Watson's convictions are affirmed.

Factual and Procedural Background

On July 14, 2014, Watson was charged in an amended complaint with attempted first-degree murder and aggravated battery by knowingly causing great bodily harm or disfigurement, a level 4 person felony, after he hit Erica Cooper in the head with a 20- pound dumbbell. A jury trial was held in July 2015. Watson was convicted of the lesser included offense of attempted second-degree murder and aggravated battery as charged.

On August 4, 2015, Watson's attorney filed a motion for new trial pursuant to K.S.A. 22-3501. He argued a new trial was warranted because: (1) multiple jurors were noticeably sleeping during trial; (2) an employee of the District Attorney's Office was in the courtroom with the jury during deliberations while Watson and his attorney were not present; (3) the State's attorney violated the court's pretrial restrictions by approaching the jury box, banging the bloody dumbbell on the rail separating the jury and courtroom, and then left the dumbbell there during her rebuttal; (4) the burden of proof instruction did not clearly explain "beyond a reasonable doubt," so the court should have used Watson's requested instruction; (5) cumulative trial error denied Watson his right to a fair trial; and (6) the State failed to prove Watson guilty beyond a reasonable doubt. On August 13, 2015, Watson also filed a pro se motion for new trial.

On September 16, 2015, the trial judge addressed and denied Watson's motions. Watson filed a timely notice of appeal. The pertinent factual circumstances will be set forth in the discussion of each of the issues raised by Watson in his appeal.

2 The trial court did not err in denying Watson's motion for new trial.

An appellate court reviews the district court's decision on a motion for new trial for an abuse of discretion. State v. Holt, 298 Kan. 469, 473, 313 P.3d 826 (2013). A judicial action constitutes an abuse of discretion if (1) no reasonable person would take the view adopted by the trial court; (2) is based on an error of law; or (3) is based on an error of fact. State v. Marshall, 303 Kan. 438, 445, 362 P.3d 587 (2015). The party asserting the trial court abused its discretion bears the burden of showing such abuse of discretion. State v. Robinson, 303 Kan. 11, 90, 363 P.3d 875 (2015), cert. denied 137 S. Ct. 164 (2016).

Listening to the 911 Call During Deliberations

Watson first argues that he had a right to be present when the jury reconvened in the courtroom during deliberations to listen to the recording of his 911 call. In the alternative, he argues the State's trial assistant should have not been in the room to operate the computer on which the evidence was contained. In essence, he is arguing that the trial court abused its discretion based on an error of law, a question over which we exercise unlimited review. See State v. Herbel, 296 Kan. 1101, 1106-07, 299 P.3d 292 (2013). The State counters that under K.S.A. 2016 Supp. 22-3420(c) and the caselaw developed from that statute, Watson did not have a right to be present while the jury listened to the 911 call during deliberations, and, in any event, he waived any right to be present.

Before the jury retired for deliberation, the parties agreed that exhibits which were not demonstrative would go back with the jury for deliberation. The State's attorney clarified the procedure for the 911 tape:

3 "MS. AHSENS: With respect to the 911 call that is an exhibit that is going to go back with them but they won't be able to play it. This laptop has stuff on it from other cases and that laptop cannot go back but it's attached to this. If they want to hear the 911 call, we'll leave it open and Karla can stick it in there and play it. "ADMINISTRATIVE ASSISTANT: He just said— "MS. AHSENS: It's not a readback, it's an exhibit. That's the way we've done it for previous trials."

Watson's trial attorney did not object, and the district court clarified that the 911 call would be played in the courtroom because that was where the equipment to play it on was located.

Criminal defendants have a right, protected by statute and the Sixth Amendment to the United States Constitution, to be present at every critical stage of a trial, including whenever the court communicates with the jury. Herbel, 296 Kan. at 1106-07. In Herbel, the jury was ushered back into the courtroom to view portions of a taped interview that had been admitted at trial. The judge conversed with the jurors and directed the tape to be played. On appeal, the Kansas Supreme Court found that the interaction between judge and jury outside the presence of the defendant violated his rights as it constituted a critical stage of trial. 296 Kan. at 1007-09. Here, unlike in Herbel, the judge did not enter the courtroom nor did he have any physical or verbal interactions with the jurors outside Watson's presence.

In State v. Montanez, No. 111,149, 2015 WL 2342382, at *3 (Kan. App. 2015) (unpublished opinion), the court noted that at the time Herbel was decided, K.S.A. 22- 3420 required evidence to be exhibited to the jury "in the presence of the defendant unless he voluntarily absents himself." However, in a subsequent 2014 amendment, which was held to apply retroactively, the legislature clarified that the defendant's presence "is only required when the district court considers a written question from the

4 jury about instructions or evidence or a request to rehear testimony." 2015 WL 2342382, at *3; see K.S.A. 2016 Supp. 22-3420(d).

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