State v. Lane
889 P.2d 929 · Washington Supreme Court · 1995
Facts
In November 1987, Jeffrey Lane and Jonathon Woods broke into Eva Wolfe’s home while evading police, holding her against her will for two hours. After pleading guilty to criminal trespass and serving jail time, they were released in March 1988. On April 20, 1988, Lane, Woods, and Wayne Anderson robbed Brian Cook at gunpoint. On April 30, 1988, the three defendants returned to Wolfe’s home, cut her phone lines, forced entry, and abducted her. They forced Wolfe into the trunk of her car, drove her to a remote part of Fort Lewis Military Reservation, made her write a $500 check, and then shot her multiple times, severing her leg, before delivering a fatal shot to her head. They left her body, picked up Robert Hipkins, and later that night, Woods shot Juan Green during a drug transaction. Police placed the defendants under surveillance at Anderson’s house, and a month later, Woods confessed and led police to Wolfe’s body.
Procedural history
Defendants Lane, Woods, and Anderson were convicted at trial, with Lane and Woods found guilty of aggravated first degree murder, and Anderson of first degree felony murder. All three appealed, and the Court of Appeals affirmed Woods’ convictions but reversed Lane’s aggravated first degree murder conviction and several of Anderson’s convictions. The State and Jonathon Woods then petitioned this court for review.
Issue
The court addressed whether the trial court properly admitted evidence of noncharged criminal activity under ER 404(b) and whether the trial court’s remarks to the jury regarding a State’s witness constituted an impermissible comment on the evidence under the Washington State Constitution.
Holding
The court held that the trial court properly admitted the evidence of "other acts" committed within the same proximate time-frame as the charged crimes. It also held that the trial judge impermissibly commented on the evidence, but this error was harmless as to all three Defendants due to overwhelming untainted evidence. The Court of Appeals decision was reversed in part and affirmed in part, reinstating the defendants' convictions on all six counts.
Rule
ER 404(b) generally prohibits evidence of other crimes to prove character but allows it for purposes like motive, intent, or plan. The "res gestae" or "same transaction" exception permits such evidence to complete the story of the crime by showing its immediate context, requiring relevance to a material issue and probative value outweighing prejudice. A judicial comment on evidence, prohibited by Const. art. 4, § 16, occurs if the court's attitude toward a disputed issue is inferable, and is presumed prejudicial unless the State shows no prejudice resulted. Constitutional error is harmless if untainted evidence is overwhelming or the remark could not have influenced the jury.
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