State Of Washington, V. Jamie Michael Engel, 80987-3

In 2017 R.C., homeless and engaged in sex work, met Jaime Michael Engel (nicknamed “Tap Out”) and twice entered motel rooms with him; the second encounter at the Wallingford Inn resulted in prolonged forcible oral and vaginal rape with threats.
R.C. told friends and Aurora Commons staff the next day; she gave a bag containing her underwear and swabs to staff, who notified police; R.C. later identified Engel from a photomontage.
The State charged Engel with two counts of second-degree rape (one count later severed); after a jury trial on count one (R.C.), Engel was convicted and later pleaded guilty to a third-degree rape count involving other victims.
Engel was sentenced to an indeterminate term (270 months to life) on count one and concurrent 60 months on the third-degree rape plea; he appealed.
On appeal Engel argued (1) the court erred by denying a mistrial after an excluded “bad date list” was mentioned, (2) the court erred by admitting testimony about prior sexual harassment of R.C., (3) ineffective assistance because counsel did not object to exclusion of Engel’s presence on a motel “no rent list,” and (4) cumulative error.

Issue	Engel's Argument	State/Court's Argument	Held
Whether denial of mistrial was erroneous after witness mentioned an excluded “bad date list”	Testimony violated pretrial exclusion and was prejudicial; mistrial needed	Mention was brief, cut off on objection, and jury instructed to disregard; no prejudice shown	Denial of mistrial affirmed — no abuse of discretion (no prejudice)
Whether testimony that R.C. had been sexually harassed years earlier was inadmissible as irrelevant/prejudicial	Prior harassment irrelevant and unfairly prejudicial	Evidence explained how R.C. became homeless and in sex work; probative of her credibility and background	Admission affirmed — relevant and probative for credibility; ER 401/403 balanced in favor of admissibility
Whether counsel was ineffective for not objecting to exclusion of Engel’s placement on motel "no rent list"	Excluding that evidence prevented defense theory that threats were to conceal other misconduct, not to force sex; counsel deficient	Counsel made a tactical choice to avoid prejudicial speculation about reasons for no-rent status and used other evidence to advance theory	Ineffective assistance claim denied — conduct was legitimate trial strategy and no prejudice shown under Strickland/McFarland
Whether cumulative error requires reversal	Combined errors deprived Engel of fair trial	No significant errors occurred to accumulate	Cumulative-error claim fails — no reversible errors found

State v. Emery, 174 Wn.2d 741 (2012) (standard for mistrial and prejudice inquiry)
State v. Hopson, 113 Wn.2d 273 (1989) (mistrial framework)
State v. Darden, 145 Wn.2d 612 (2002) (standard for admissibility of relevant evidence)
State v. Powell, 126 Wn.2d 244 (1995) (ER 403 abuse-of-discretion review)
State v. Roberts, 25 Wn. App. 830 (1980) (credibility of accuser in sex-crime prosecutions)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective assistance test)
State v. McFarland, 127 Wn.2d 322 (1995) (applying Strickland in Washington)
State v. Kyllo, 166 Wn.2d 856 (2009) (trial tactics not deficient performance)
State v. Classen, 4 Wn. App. 2d 520 (2018) (ineffective-assistance burden on appeal)
State v. Jackson, 150 Wn. App. 877 (2009) (cumulative-error doctrine)