State of Washington v. William John Wright
33217-9
| Wash. Ct. App. | May 2, 2017Background
- Deputies arrested informant Charles Castro in October 2013; Castro gave a recorded, Mirandized interview identifying William Wright as a long‑time meth seller, describing recent purchases, locations on Wright's property where drugs/firearms were kept, and overhearing talk about a stolen Dodge pickup.
- Deputy Jordan Bowman used Castro's identified statements (and partial corroboration concerning a second man, Ackaret) to obtain a warrant to search four contiguous parcels belonging to Wright for drugs, firearms, a mid‑90s Dodge Ram, and related items.
- Execution of the warrant uncovered methamphetamine residue, scales, hundreds of small bindle baggies (many bearing a red smiley face), hydrocodone, cash, firearms in a consenting trailer search, three stolen vehicles and a stolen ATV.
- The recorded interview was overwritten by the department's 45‑day auto‑erase policy because no copy was requested; defense later interviewed Castro and learned he had expressed hatred and a desire for vigilante revenge against Wright (not included in the affidavit).
- Wright moved for a Franks hearing, suppression, and dismissal for destruction of evidence; motions were denied. At trial the court admitted a photo of a used smiley‑face baggie from a trailer, overruled most vouching objections, and the jury convicted Wright of possession with intent to deliver methamphetamine and four counts of possession of stolen vehicles. The court imposed fines and LFOs. Wright appealed.
Issues
| Issue | Wright's Argument | State's Argument | Held |
|---|---|---|---|
| Denial of Franks hearing (omitted informant statements) | Bowman omitted Castro's expressed hatred/revenge motive; omissions were material and made in reckless disregard, entitling Wright to a Franks hearing | Omitted material actually strengthened probable cause; affidavit already disclosed Castro "didn't usually like" Wright; omissions not material or intended to mislead | Denial affirmed — omissions not material and inclusion would not negate probable cause; no showing of recklessness |
| Sufficiency of warrant under Aguilar‑Spinelli & particularity | Informant unreliable; affidavit fails basis of knowledge and veracity prongs; warrant too broad | Castro gave detailed first‑hand observations, recent purchases, firearms locations, and admitted crimes; named informant, statements against penal interest, corroboration satisfy prongs; nexus to places and items established | Affidavit met Aguilar‑Spinelli; nexus and particularity requirements satisfied; suppression denied |
| Dismissal for destruction of recording (due process) | Lost recording was material/exculpatory; its destruction was bad faith | Recording was not obviously exculpatory; defense obtained equal/greater details via defense counsel interview; no evidence police knew of exculpatory value or acted to conceal | Denial affirmed — recording not shown to be material/exculpatory and failure to preserve not shown to be in bad faith |
| Prosecutorial misconduct (vouching) and prejudicial remarks in closing | Prosecutor vouched for informant ("the deal was worth it"), warranting mistrial | Comments were a response to defense argument; only one ambiguous remark potentially improper and court instructed jury to disregard; no prejudice shown | No reversible misconduct; court did not abuse discretion in denying mistrial; instruction to disregard cured any potential prejudice |
Key Cases Cited
- Franks v. Delaware, 438 U.S. 154 (1978) (omission or falsehood in warrant affidavit requires hearing if defendant makes preliminary showing of materiality and recklessness)
- Aguilar v. Texas, 378 U.S. 108 (1964) (two‑prong informant reliability test: basis of knowledge and veracity)
- Spinelli v. United States, 393 U.S. 410 (1969) (application of Aguilar two‑prong test to informant tips)
- Illinois v. Gates, 462 U.S. 213 (1983) (establishes totality‑of‑circumstances test; discussed for context of federal standards)
- State v. Chenoweth, 160 Wn.2d 454 (2007) (named informants, statements against penal interest, and corroboration support veracity)
- State v. Jackson, 102 Wn.2d 432 (Wash. 1984) (Washington adherence to Aguilar/Spinelli framework)