State Of Washington v. Bonnie M. Teafatiller
47163-9
| Wash. Ct. App. | Mar 7, 2017Background
- On Aug. 16, 2013, Bonnie Teafatiller rode in a car with Allen Jenkins (driver), Bruce Marbley, and Kayla Wadley; a dispute arose over payment for Teafatiller’s assistance locating sex workers.
- During the argument, Teafatiller drew a gun and demanded Jenkins and Marbley go to an ATM; Jenkins refused and drove erratically.
- Three shots were fired from the backseat: one out the window, one into the dashboard, and one through Jenkins’ neck; Jenkins drove to a nearby store and survived.
- At a bench trial Teafatiller claimed Wadley was the shooter; the trial judge found Jenkins, Marbley, and Wadley more credible and convicted Teafatiller of attempted second-degree murder, two counts of first-degree assault, attempted first-degree robbery, unlawful possession of a firearm in the second degree, plus firearm enhancements.
- The court imposed $2,800 in discretionary legal financial obligations (LFOs); Teafatiller appealed raising (1) due process challenge to the court’s application of the beyond-a-reasonable-doubt standard and (2) challenge to imposition of LFOs without an individualized ability-to-pay inquiry.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judge applied beyond-a-reasonable-doubt standard | Teafatiller: judge’s findings show a lower-than-required standard; findings reflect conclusory or improper reasoning | State: judge’s findings are credibility determinations consistent with applying the higher standard | Court held judge applied the beyond-a-reasonable-doubt standard; credibility findings are not reversible if not arbitrary |
| Whether court erred by imposing discretionary LFOs without individualized inquiry | Teafatiller: trial court used boilerplate inquiry and failed to consider ability to pay, including incarceration and long sentence | State: (implicit) LFOs imposed appropriately | Court held the record lacks an individualized ability-to-pay inquiry; reversed LFOs and remanded for proper inquiry |
Key Cases Cited
- In re Winship, 397 U.S. 358 (1970) (State must prove every element beyond a reasonable doubt)
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency review ensures rational application of beyond-a-reasonable-doubt standard)
- State v. Berg, 181 Wn.2d 857 (2014) (sufficiency inquiry and standard of review for factfinder’s application of constitutional standard)
- State v. Blazina, 182 Wn.2d 827 (2015) (trial court must make individualized inquiry into ability to pay before imposing discretionary LFOs)
- State v. Marks, 185 Wn.2d 143 (2016) (procedural context allowing appellate consideration of LFO issues post-Blazina)
- State v. Camarillo, 115 Wn.2d 60 (1990) (credibility determinations are for the trier of fact and not reviewable on appeal)