State Of Washington v. Euran J. Woods
198 Wash. App. 453
| Wash. Ct. App. | 2017Background
- Euran Woods and Brittany Englund had a volatile, abusive relationship in which Woods physically abused Englund and forced her into prostitution beginning in 2011; Englund delayed reporting due to fear, shame, and manipulation.
- The State charged Woods with second-degree assault by strangulation for the September 2011 incident; jury convicted and court imposed a standard-range sentence (9 months jail, 12 months community custody).
- At pretrial the State sought to admit evidence of prior assaults and of Woods forcing Englund into prostitution to explain her reluctance to seek help and to show relationship dynamics; the court excluded an April 2012 assault but admitted August 2011 strangulation and prostitution evidence under ER 404(b).
- Trial counsel did not object to the prostitution evidence and declined to request a limiting instruction specific to the pimping testimony; counsel later filed an Anders brief and withdrew; new appointed counsel raised issues on appeal.
- On appeal Woods argued the pimping evidence was irrelevant and unduly prejudicial (including a new claim that it appealed to racial bias) and that counsel was ineffective for failing to object and for not requesting a limiting instruction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of prostitution/pimping evidence under ER 404(b) | State: prior acts admissible to explain victim's fear, motive, intent, and credibility/context for why she did not seek help | Woods: evidence irrelevant, highly prejudicial, and (on appeal) appealed to racial bias | Court: admissible; trial court properly found prior acts by preponderance, relevance to relationship dynamics and victim's state of mind outweighed prejudice; racial-bias claim unsupported by record |
| Exclusion of April 2012 assault evidence | State: not contested as highly prejudicial/not relevant to charged act? (State sought admission of prior assaults generally) | Woods: argued prior-act evidence in general was prejudicial | Court: excluded April 2012 assault as overly prejudicial and not relevant to charged conduct (no error) |
| Ineffective assistance for failure to object to prostitution evidence | Woods: counsel deficient for not objecting, causing admission of prejudicial evidence | State: counsel made tactical choice to defer objection to preserve cross-examination value; evidence was properly admissible anyway | Court: no ineffective assistance — counsel’s decision was a plausible trial tactic and evidence was admissible so no prejudice shown |
| Ineffective assistance for failing to request a limiting instruction | Woods: counsel’s failure prevented curbing jury misuse of prior-act evidence | State: strategic reasons existed (defense theory relied on truth of prostitution evidence; separate limiting instruction might reemphasize damaging testimony) | Court: no deficient performance or prejudice; trial court gave limiting instruction on prior assaults and prosecutor framed prostitution evidence as limited-purpose evidence, jury likely so instructed |
Key Cases Cited
- Grant v. State, 83 Wn. App. 98 (1996) (domestic-violence dynamics can bear on victim credibility and justify prior-act evidence to explain victim behavior)
- Baker v. State, 162 Wn. App. 468 (2011) (prior strangulations admissible to inform jury of relationship dynamics and credibility issues)
- Vy Thanq v. State, 145 Wn.2d 630 (2002) (ER 404(b) admissibility framework: proof of misconduct, purpose, relevance, and probative-prejudice balancing)
- Gresham v. State, 173 Wn.2d 405 (2012) (prior-bad-act evidence may be admissible for noncharacter purposes depending on relevance and balancing)
- Strickland v. Washington, 466 U.S. 668 (1984) (two-part standard for ineffective assistance: deficient performance and prejudice)