State v. Watt

CourtCourt of Appeals of Kansas
DecidedOctober 16, 2015
Docket112266
StatusUnpublished

This text of State v. Watt (State v. Watt) 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. Watt, (kanctapp 2015).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 112,266

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

KATLIN ANN WATT, Appellant.

MEMORANDUM OPINION

Appeal from Lyon District Court; MERLIN G. WHEELER, judge. Opinion filed October 16, 2015. Affirmed.

Rick Kittel, of Kansas Appellate Defender Office, for appellant.

Sarah E. Washburn, assistant county attorney, Marc Goodman, county attorney, and Derek Schmidt, attorney general, for appellee.

Before GREEN, P.J., HILL, J., and TIMOTHY G. LAHEY, District Judge, assigned.

Per Curiam: Defendant Katlin Watt appeals her conviction for conspiracy to distribute methamphetamine, unlawful use of a communication facility, and operating a motor vehicle without a license. Finding no reversible error, we affirm Watt's convictions.

1 FACTS OF THE CASE

On October 22, 2013, Laken Criqui and Watt engaged in a Facebook conversation in which they agreed to meet in Emporia where Criqui would buy a gram of methamphetamine from Watt for $100. Based on this conversation, Criqui drove to Emporia from her home in Lebo to meet Watt. Criqui texted Watt upon her arrival in Emporia and they arranged to meet at The Dugout on 12th Avenue. Watt confirmed via text message that she wanted "a bill," which Criqui understood to mean $100. The two women met up at the Dugout where Criqui got into Watt's car and Watt drove to Hardee's to purchase some food. On the way back to the Dugout, Criqui gave $100 to Watt with the expectation that she would receive a gram of methamphetamine in return.

Emporia Police Officer Rob Shipley saw Watt driving her car. Believing she did not have a valid driver's license, he began following Watt's car. He followed it to the Dugout where he saw Watt and Criqui switch seats. Shipley continued to follow the car until Criqui stopped in front of a residence on Cottonwood Street. Shipley was familiar with the residence on Cottonwood Street due to prior incidents there involving methamphetamine possession and sale. The officer pulled in behind Watt's car and activated the lights on his patrol car. Watt got out of the car and headed toward the residence. Shipley asked Watt to come back to his patrol car to speak to him. Watt confirmed that she did not have a driver's license, and according to Shipley, she appeared anxious and indicated more than once that she wanted to go inside the residence to eat her food. After placing Watt under arrest for driving without a license, Shipley spoke to Criqui, who advised of the arrangement with Watt to purchase methamphetamine. No drugs were found on Watt, Criqui, or in Watt's car.

The State subsequently charged Watt with one count each of conspiracy to distribute methamphetamine, unlawful use of a communication facility, and operating a motor vehicle without a license. A jury convicted Watt as charged. The district court

2 sentenced Watt to a controlling 24-month prison term with a postrelease supervision term of 24 months. Watt timely appeals.

On appeal, Watt contends: (1) The evidence was insufficient to support her conviction of conspiracy to distribute methamphetamine, (2) the oath sworn to by the jury was coercive and deprived her of her constitutional rights to due process and a fair trial, (3) the district court committed reversible error by instructing the jury about the costs associated with a mistrial, (4) the district court erred in admitting evidence of prior drug activity at the residence on Cottonwood Street, and (5) the release of exhibits to the jury during deliberations violated her constitutional rights to be present and to have the trial judge be present at all critical stages of the trial. Each of these allegations is addressed in turn.

SUFFICIENCY OF THE EVIDENCE

Watt asserts that the evidence was insufficient to support her conviction of conspiracy to distribute methamphetamine because the State failed to prove she committed an overt act in furtherance of the conspiracy.

When the sufficiency of the evidence is challenged in a criminal case, this court reviews all the evidence in the light most favorable to the prosecution to determine whether the court is convinced that a rational factfinder could have found the defendant guilty beyond a reasonable doubt. State v. Williams, 299 Kan. 509, 525, 324 P.3d 1078 (2014). In determining whether there is sufficient evidence to support a conviction, the appellate court will not reweigh the evidence, resolve evidentiary conflicts or make witness credibility determinations. 299 Kan. at 525.

Conspiracy requires proof that the defendant entered into an agreement with another person to commit or assist in the commission of a crime and that the defendant or

3 the co-conspirator committed an overt act in furtherance of the conspiracy. See K.S.A. 2014 Supp. 21-5302(a).

"An overt act which completes the crime of conspiracy is something apart from the conspiracy. It is an act to effect the object of the conspiracy but it need be neither a criminal act, nor the crime that is the object of the conspiracy. However, it must accompany or follow agreement and must be done in furtherance of the object of the agreement." State v. Crockett, 26 Kan. App. 202, Syl. ¶ 4, 987 P.2d 1101 (1999).

Conversations among co-conspirators in forming and planning the conspiracy are not overt acts in furtherance of a conspiracy. 26 Kan. App. 2d 202, Syl. ¶ 5. Instead, "[i]t must be shown the defendant took a step beyond the mere preparation so that some appreciable fragment of the crime was committed." 26 Kan. App. 2d at 204.

In the present case, the State alleged in the complaint/information that Watt had conspired with Criqui to commit the crime of distribution of methamphetamine and that "an overt act, to wit: taking money and agreed upon a price, in furtherance of the conspiracy was committed."

Watt argues that agreeing on a price is merely a part of the conversation in forming and planning a conspiracy and is not an overt act in furtherance of the conspiracy. She further contends that the evidence was insufficient to show that she committed an overt act by taking money from Criqui, as no evidence of drugs or large amounts of cash were found in Watt's possession or that she was even in possession of the $100 Criqui testified she gave to Watt.

The State presented evidence that Watt and Criqui came to an agreement regarding the distribution of methamphetamine by discussing the price, the amount of methamphetamine, and where to meet to make the exchange. Based on this agreement,

4 Criqui drove from Lebo to Emporia to meet Watt. Criqui testified that she gave Watt $100 and expected to receive a gram of methamphetamine in exchange. The exchange of money is an overt act in furtherance of the conspiracy to distribute methamphetamine. Following Watt's arrest, she was found to be in possession of five $20 bills. Watt suggests that the State's evidence is lacking because Criqui testified she gave Watt a $100 bill, not five $20 bills. But it is up to jury to weigh the evidence and assess witness credibility. See Williams, 299 Kan. at 525. Viewed in the light most favorable to the prosecution, this evidence is sufficient to prove the existence of an overt act in furtherance of the conspiracy to distribute methamphetamine.

THE JURY'S OATH

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State v. Watt, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-watt-kanctapp-2015.