State of Washington v. Francisco J. Resendez Miranda, 33958-1

In August 2014 three victims (two adults and a pregnant woman) were found murdered on a Benton County farm; two victims were shot at close range, the third was shot while fleeing and showed signs of strangulation and struggle.
Investigation focused on Francisco Miranda and his family; Miranda was the only family member arrested. Lay witnesses testified Miranda admitted involvement and was present with victims the night before; one witness said Miranda borrowed a loaded .38 handgun that later showed blood spatter when returned.
Physical evidence included a blood-stained tank top in Miranda's apartment that forensic testing tied to one victim; the suspect gun was thrown in a river and unavailable for analysis.
Miranda was charged with three counts of first-degree murder with a multiple-victim aggravator; the State also sought a pregnancy aggravator but the jury found Miranda did not know the victim was pregnant.
At trial the court admitted an autopsy photo of the full-term fetus over Miranda's objection, gave an accomplice liability instruction, and denied Miranda's request for lesser included (second-degree murder) instructions; jury convicted on all counts and imposed life without parole.

Issue	State's Argument	Miranda's Argument	Held
Admissibility of autopsy photograph	Photo aids medical testimony and shows pregnancy would be apparent; probative value outweighs prejudice	Photo is gruesome and prejudicial; admission inflames jury	Admission was not an abuse of discretion; probative value justified and jury’s rejection of pregnancy aggravator shows no improper prejudice
Accomplice liability instruction	Evidence supported that Miranda procured the gun, participated in abduction, and confessed to firing; instruction appropriate	Insufficient evidence Miranda was a major participant or aiding others so instruction was unwarranted	Sufficient evidence existed to justify accomplice instruction; jury could find Miranda liable as principal or accomplice
Denial of lesser included (second-degree murder) instruction	N/A (State argued evidence showed premeditation)	Trial court should have instructed on second-degree murder because jury might disbelieve premeditation	Denial affirmed; no affirmative evidence supported a non-premeditated killing and speculation cannot justify the instruction
Pregnancy aggravator application	N/A	Jury did not find Miranda knew victim was pregnant; Miranda argued prejudice from photo could have influenced this finding	Jury found no knowledge; court noted this outcome undercuts any claim the photo improperly inflamed the jury

State v. Yates, 161 Wn.2d 714 (Wash. 2007) (standard for admitting autopsy photographs under ER 403)
State v. Whitaker, 133 Wn. App. 199 (Wash. Ct. App.) (autopsy photos assist jury in understanding medical testimony)
State v. Gentry, 125 Wn.2d 570 (Wash. 1994) (use of autopsy photos to show injury extent and elements like intent)
State v. Crenshaw, 98 Wn.2d 789 (Wash. 1983) (warning against cumulative or unnecessarily prejudicial autopsy photos)
State v. Stackhouse, 90 Wn. App. 344 (Wash. Ct. App.) (admission may be upheld where purpose is explanatory, not inflammatory)
State v. Lazcano, 188 Wn. App. 338 (Wash. Ct. App.) (elements for accomplice liability)
State v. Munden, 81 Wn. App. 192 (Wash. Ct. App.) (appellate sufficiency review for accomplice instruction)
State v. Fernandez-Medina, 141 Wn.2d 448 (Wash. 2000) (standard for factual basis of lesser included instructions)
State v. Condon, 182 Wn.2d 307 (Wash. 2015) (abuse-of-discretion review for denial of lesser included instruction)