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.Justice Nakayama’s Dissent. Justice Nakayama believed that the circuit court did not abuse its discretion in preventing Williams from testifying about Quindt’s boasts. Justice Nakayama pointed out that the defendant’s right to present a defense is “not an unmitigated right to present any evidence he wishes in whichever manner he chooses.” She took issue with the majority’s characterization of the circuit court’s rulings. She noted that the circuit court allowed Williams to testify about some of Quindt’s threats, but not all of it. That, for her, made this a matter of degree. “Did the circuit court’s alteration and exclusion of some of Quindt’s alleged statements amount to error that was an abuse of discretion? And if so, is it reasonably possible that the exclusions contributed to Williams’s conviction?” Justice Nakayama’s answers to both questions is no. Chief Justice Recktenwald joined.