The Right to Present a Complete Defense Requires Telling it in your own Words
State v. Williams (HSC June 15, 2020)
Background. Joshua Williams was charged with the attempted
murder of David Quindt, Jr. Before trial, Williams filed notice pursuant to HRE
Rule 404(b) of prior bad acts. Williams intended to present evidence that
Quindt told him about his violent past in an effort to explain why Williams feared
for his life. Quindt would boast about doing time for murder in California,
doing “hard time,” that he knows how to fight because of the time he spent in
jail, he knows “gang-bangers” and gang members, he has experience with violence
due to being in jail, he “got away with murder” by beating the charge, and that
he did the crime, but still “got off on a technicality.” The prosecution
opposed the evidence in a motion in limine. The circuit court presided by the
Hon. Judge Karen Ahn, granted the motion in part and allowed Williams to
testify about Quindt’s murder conviction and how he had to learn to fight to
survive in jail. The circuit court ordered Williams that he could not testify
about what Quindt told him.
At trial, the prosecution
presented evidence that Williams was renting a room from Quindt. He was living
there with his son. Before the altercation between Quindt and Williams, Quindt
felt “tired, exhausted, and frustrated.” He was working on tattoo for Williams
that took longer than expected. They had an argument in Quindt’s car. Williams
got irritated and began yelling. Quindt said, “please don’t disrespect me.” Williams
jumped out of the vehicle. Quindt stopped and told him to get back inside.
Williams hopped in the backseat. The argument resumed. At that point Quindt was
struck in the face with a knife. Williams raised self-defense. The jury found
Williams guilty as charged; he was sentenced to life imprisonment with the
possibility of parole. The ICA affirmed.
The Constitutional Due
Process Right to Present a Complete Defense. “Few rights are more fundamental than that
of an accused to present witnesses in his own defense.” Chambers v.
Mississippi, 410 U.S. 284, 302 (1973). The right to a fair trial is deemed “fundamental”
under the Due Process Clause in the Fourteenth Amendment and Article I, Section
5 of the Hawai'i Constitution. This includes the right to present a “complete
defense.” State v. Matafeo, 71 Haw. 183, 185, 787 P.2d 671, 672 (1990). The
defendant’s right to present his or her own version of what happened is “basic
to our system of jurisprudence.” In re: Oliver, 333 U.S. 257, 273
(1948).
The HSC held that the circuit
court erred in refusing to allow Williams to testify about Quindt’s bragging
and boasts about prison life and getting away with murder. The statements went
directly to Williams’s state of mind and helped explain why he felt it
necessary to resort to lethal force—an element of self-defense. HRS § 703-304.
Moreover, Williams should have been able to testify without the circuit court’s
curtailment. “It is for the jury to evaluate the strength of the defendant’s
claim of self-defense with full opportunity to observe a defendant’s complete
presentation of the evidence that allegedly caused the accused to act in
self-defense.” It was not enough to allow only a limited part of Williams’s
state of mind.
Finally, these errors were
not harmless beyond a reasonable doubt. The HSC held that infringing on the
right to present a complete defense created “a reasonable possibility that the
error complained of might have contributed to the conviction.” State v.
Kassebeer, 118 Hawai'i 493, 505, 193 P.3d 409, 421 (2008). The HSC vacated
the judgment and remanded the case for a new trial.
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