State v. Watson

CourtCourt of Appeals of Kansas
DecidedAugust 2, 2019
Docket118710
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 2019).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 118,710

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

JASMON DEVAR WATSON, Appellant.

MEMORANDUM OPINION

Appeal from Wyandotte District Court; BILL KLAPPER, judge. Opinion filed August 2, 2019. Affirmed in part and vacated in part.

Jennifer C. Roth, of Kansas Appellate Defender Office, for appellant.

Rachel L. Pickering, assistant solicitor general, and Derek Schmidt, attorney general, for appellee.

Before HILL, P.J., STANDRIDGE, J., and NEIL B. FOTH, District Judge, assigned.

PER CURIAM: Following a jury trial, Jasmon Devar Watson was convicted of making a false claim to the Medicaid program. As a result of his conviction, the district court ordered Watson to pay $13,077.22 in restitution. Watson appeals from both his conviction and the order of restitution. For the reasons stated below, we affirm Watson's conviction but vacate the district court's order of restitution.

1 FACTS

During the time period from March 2011 to July 2015, Watson worked two part- time jobs in Kansas City, Kansas. First, he was employed as a transitional living skills assistant with Best Choice Home Health Care Agency. In this position, Watson provided life activity training and services to patients with traumatic brain injuries. Watson's employer, Best Choice, contracted with Medicaid to pay its employees for these services. In addition to his job at Best Choice, Watson also worked part-time as a store clerk for QuikTrip.

After being alerted of the possibility that Watson's work times in these two jobs overlapped, Special Agent Darren Brown in the Medicaid Fraud and Abuse Division of the Kansas Attorney General's Office launched an investigation into possible Medicaid fraud. As part of the investigation, Agent Brown requested Watson's personnel records and client documentation from both Best Choice and QuikTrip.

Cindy Ludwig, an analyst in the Kansas Attorney General's Office, used the records and documentation received by Agent Brown to create a table that identified overlapping time between the hours Watson spent working at QuikTrip and the hours he spent providing services to Medicaid beneficiaries through Best Choice. This table established 247 instances of overlapping time from January 1, 2013, to July 31, 2014. Based on the number of overlapping hours, the number of overlapping units, and the applicable unit rate, Ludwig calculated that Watson was paid $13,077.22 for hours he reported spending with a Medicaid beneficiary when he was actually working those hours at QuikTrip.

On July 6, 2015, the State charged Watson with one count of making a false claim to the Medicaid program and one count of felony theft. The matter proceeded to trial, where the State presented four witnesses: Kim Reynolds, a traumatic brain injury

2 program manager for the Kansas Department for Aging and Disability Services; Special Agent Brown; Corey Hanover, Watson's QuikTrip Manager; and Ludwig. In addition to testimony from these witnesses, the State introduced several exhibits into evidence, including Ludwig's table showing the overlapping hours, Watson's personnel records, and other documentation from QuikTrip and Best Choice.

Watson testified on his own behalf and did not deny that his Best Choice and QuikTrip hours overlapped. Instead, he claimed that he worked his Best Choice hours around his QuikTrip schedule. Watson insisted he always worked the total number of hours documented on his Best Choice time sheet but not necessarily at the times noted. Watson explained that the reason he submitted inaccurate time sheets was because it was time-consuming to keep changing the Best Choice schedule to reflect the hours he actually worked. Watson repeatedly stated throughout his testimony that his supervisors at Best Choice were aware of what he was doing and told him to continue working in this manner. On cross-examination, however, Watson acknowledged that every time sheet he submitted to Best Choice contained a warning that "'[a]ny misrepresentation or falsification will result in Medicaid fraud and will be punishable to the full extent of the law.'"

Following Watson's testimony, the defense rested and a jury instruction conference was held. Watson objected to jury instruction 10 which stated:

"It is not a defense that others who participated in the commission of the crime have or have not been convicted of the crime, any lesser degree of the crime, or some other crime based on the same act."

Watson's objection was overruled, and the remaining instructions were approved by all parties. The jury ultimately found Watson guilty of making a false claim to the Medicaid program but was unable to reach a verdict on the charge of theft.

3 Before sentencing, Watson filed a motion for a new trial in which he reiterated his objection to jury instruction 10. The motion was denied. The court ultimately sentenced Watson to an underlying term of five months in prison but granted Watson probation for a term of 12 months.

The court also took up the issue of restitution at sentencing. The State requested Watson pay $13,077.22 in restitution. Watson argued against restitution, again insisting that he worked every hour billed to Medicaid, which meant no restitution was owed. The district court was not persuaded by Watson's argument and ordered Watson to pay the full $13,077.22 in restitution.

ANALYSIS

On appeal, Watson argues (1) the State committed prosecutorial error during its closing argument; (2) the district court erred by overruling his objection to the jury instructions; (3) cumulative errors denied him a fair trial; and (4) the district court erred by ordering him to pay restitution.

1. Prosecutorial error

We consider claims of prosecutorial error in two steps. First, we look to see whether the prosecutor erred. Second, if there was an error, we must decide whether that error prejudiced the defendant's right to a fair trial. State v. Sherman, 305 Kan. 88, 109, 378 P.3d 1060 (2016).

a. Error

Watson claims the State committed three acts of prosecutorial error during closing argument: (1) The State improperly shifted the burden of proof onto him, (2) the State

4 misstated the law regarding Medicaid fraud, and (3) the State misstated the evidence. We address each of Watson's claims of error in turn.

(1) Burden shifting

Watson claims the State committed prosecutorial error by improperly shifting the burden of proof to him during its closing argument. Burden shifting is when the prosecutor's comments shift the burden to the defendant to prove his or her innocence. "Kansas courts deem it 'improper for the prosecutor to attempt to shift the burden of proof to the defendant or to misstate the legal standard of the burden of proof.'" State v. Duong, 292 Kan. 824, 832, 257 P.3d 309 (2011) (quoting State v. Stone, 291 Kan. 13, 18, 237 P.3d 1229 [2010]).

To support his claim that the prosecutor's comments shifted the burden to him to prove his innocence, Watson points to the prosecutor's repeated comments to the jury that he failed to provide evidence in support of his testimony that he worked the hours billed to the Medicaid beneficiaries but just did not work those hours at the time listed on his time sheet. Watson argues the prosecutor's remarks went beyond the wide latitude granted prosecutors to comment on the evidence and improperly shifted the burden of proof to him. We disagree.

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State v. Watson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-watson-kanctapp-2019.