t '•": ! ' IN THE COURT OF APPEALS OF THE STATE OF WASHINGTON
STATE OF WASHINGTON, Respondent,

v. DONALD CHRISTOPHER MOORE, Appellant.

CO No. 67294-1-1 DIVISION ONE

UNPUBLISHED FILED: August 26. 2013

dA Cox, J. —We granted the State's motion for discretionary review of a King 

### (JSunty SuperiorCourt's RALJ decision. TheRALJ courtreversed Donald
CM Moore's fourth degree assault conviction after a retrial of his case in district court. 

### Ifhe Statecontends thattheRALJ courtmisapplied theStrickland v. Washington1

standard in deciding that Moore received ineffective assistance ofcounsel in his first trial. Further, the State contends that the trial testimony of a principal witness inthe first trial was properly admitted inthe second trial, satisfying the requirements of both ER 804(b)(1) and the right to confrontation underthe Sixth Amendment. We disagree with all ofthese contentions and affirm. In 2007, the State charged Moore in district courtwith fourth degree assault. The charge arose from a physical altercation between Moore and Mark 

### 1466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984).No. 67294-1-1/2 

### Storer, a tow truck driver and owner of a towing company. Moore saw that Storer
was preparing to tow his car from a parking lotat an apartment complexthat Moore was visiting. A scuffle ensued between the two, and Storer sustained physical injuries. At Moore's first jury trial, Storer testified aboutthe incident. Moore's counsel argued self-defense but not defense ofproperty. Thejury found Moore guilty as charged. Inthe first RALJ appeal, Moore argued that he received ineffective assistance ofcounsel because his counsel failed to request a "no duty to retreat" instruction and failed to present a defense of property claim. The King County Superior Court reversed Moore's conviction on the first basis, but it did not reach the second argument. That court expressly stated there was both deficient 

### performance and prejudice based on the failure to request the "no duty to retreat" instruction. Before the retrial ofMoore's case, Storer died for reasons unrelated to this
case. At the second trial, Moore moved in limine to exclude Storer's testimony from the first trial. He argued that the requirements of ER 804(b)(1), a hearsay exception forformer testimony, were not met. The district court denied this motion and admitted the former testimony. The case proceeded to a secondjury trial, and the district court instructed thejury on both self-defense and defense ofproperty. Thejury convicted Moore
as charged.No. 67294-1-1/3 

### On this RALJ appeal of his second conviction, a differentjudge of the 

### superiorcourt reversed Moore's conviction. The RALJ court determined that Moore's right to confrontation was violated and the requirements of ER 804(b)(1)
were not met when the district court admitted Storer's former testimony at the 

### second trial. In reaching this conclusion, the RALJ court determined that Moore received ineffective assistance of counsel at the first trial. Itexplained that Moore's counsel failed to "raise, explore, and request instructions on the affirmative defense ofdefense of property." The court did not expressly state 

### whetherthis deficientperformance was prejudicial, under the second prong of Strickland. 

## Wegranted the State's motionfordiscretionary review.2 INEFFECTIVE ASSISTANCE OF COUNSEL The RALJ court's decision to reverse and remand Moore's second 

### conviction is premised on its conclusion that Moore received ineffective assistance ofcounsel at his first trial. As a consequence, we first consider 

### whether we agree that Moore received ineffective assistance before addressing the evidentiary and Confrontation Clause issues. 

### The State argues that the RALJ court's conclusion that Moore's counsel in the first trial was ineffective is unsupported by the trial record. We disagree.



### 2OrderGranting Motion forDiscretionary Review entered onApril 18, 2012.No. 67294-1-1/4 To prevail on a claim of ineffective assistance ofcounsel, a defendant must show that his counsel's performance fell below an objective standard of 

### reasonableness and thatthis deficientperformance prejudiced his trial.3 The reasonableness inquiry presumeseffective representation.4 To
overcome this presumption, a defendant must show the absence of legitimate 

### strategic ortactical reasonsforthechallenged conduct.5 To show prejudice, the defendant must prove that, but forthe deficient performance, there is a reasonable probability that the outcome would have been different.6 "Failure to request an instruction on a potential defense can constitute ineffective assistance of counsel."7 Deficient Performance Adefendant may raise defense ofproperty inresponse to criminal 

### charges.8 RCW 9A.16.020 states when the use offorce toprotectproperty isnot unlawful:


### 3Strickland v. Washington. 466 U.S. at 687; State v. McFarland, 127 Wn.2d 322, 334-35, 899 P.2d 1251 (1995). 4McFarland. 127 Wn.2d at 335. 

### 5IpL at 335-36. 6In re Pers. Restraint of Pirtle. 136 Wn.2d 467, 487, 965 P.2d 593 (1998). 

### 7In re Pers. Restraint of Hubert, 138Wn. App. 924, 929, 158P.3d 1282 (2007).

### 6See, e.g.. State v.Bland. 128Wn. App. 511, 513-14, 116 P.3d428 (2005).No. 67294-1-1/5 The use, attempt, or offer to use force upon or toward the person of another is not unlawful in the following cases: (3) Whenever used by a party about to be injured, or by another lawfully aiding him or her, in preventing or attempting to prevent an offense against his or her person, ora malicious trespass, or othermalicious interference with real orpersonalproperty lawfully in his orherpossession, in case theforce is notmore 

### than is necessary.[9] Adefendant is entitled to a defense of property instruction ifthere is 

### "credible evidencetending toprove" the defense ofproperty.10 "[A] defendant must produce evidence showing that he or she had a good faith beliefinthe 

### necessity offorce and thatthatbeliefwasobjectively reasonable."11 In In re Personal Restraint of Hubert. Hubert's counsel failed to identify 

### and presentthe sole available defense to the charged crime, despite the fact that 

### there wasevidence tosupportthatdefense.12 This courtconcluded thatHubert

was denied effective assistance of counsel as a result ofthis failure and the 

### resulting prejudice.13 There, Hubert was charged with "second degree rape underthat part of the statute criminalizing sex with a person who is incapable ofconsent by reason

(Emphasis added.) 

### 10 See State v. Dvson. 90Wn. App. 433, 438, 952 P.2d 1097 (1997) (explaining when a defendant is entitled to a self-defense instruction). 11 Id 

### 12 138 Wn.App. 924, 932, 158 P.3d 1282 (2007). 13 Id.No. 67294-1-1/6 

### ofbeing physically helpless."14 An affirmative defense tothis charge isthat the defendant reasonably believed that the person was capable ofconsent.15 Hubert testified that he believed that the alleged victim was awake during the sexual 

### encounter.16 Despite thisevidence, Hubert's attorney did not raise the affirmative defense.17 Further, hisattorney admitted that he "'was notfamiliar' with the statutory defense until Hubert's appellate counsel brought itto his attention."18 This court concluded that "[cjounsel's failure to discover and advance the 

### defense wasplainly deficient performance."19 Here, Moore's counsel in his first trial argued that Moore acted in selfdefense against Storer. But Moore's counsel failed either to request a defense of property instruction or argue this defense. This failure was in addition to counsel's demonstrated failure to either argue or request an instruction regarding "no duty to retreat." During the first trial, Moore's testimony showed that his theories of selfdefense and defense of property were based on intertwined factual bases. Moore testified that the altercation arose from pushing and shoving when Storer
was preparing to tow Moore's car. 

### 14Id, at 927. 

### 15Id at 929. 

### 16Id, 17id. 18 Id, 19 Id. at 930.No. 67294-1-1/7 He also testified that he was defending his "body" and "property" during the incident. He believed Storer was "stealing" his car, and he "choose not to have [his] property stolen": When he, when Iasked to move my car, it's my legal right to move my car, Washington State Patrol. That's the rule. When he put the hook on my car and Iwentto remove it, after asking him to move 

### my car, then he wasstealing my car.1201 Moore testified that when he removed a hook used for towing his car, Storer jumped on his back and struck him. Moore claimed he fell to the ground and Storerwas standing over him withthe hook. He felt like Storerwas going to hit him with the hook, so Moore hit Storer. When Moore saw Storer preparing to tow his car, Moore claimed that he told Storer that his newborn son's birth certificate was in the backseat of his car. Then, he testified that Storer responded, "I don't give a f**\ I'm taking it 

### anyways."21 Objectively viewed, this testimony fits the criteria for defense of property: Moore claims he was attempting to prevent "a malicious trespass, or other malicious interference with . . . personal property lawfully in his . . . possession" 

### and theforce was "notmore than isnecessary."22 Despite thistestimony and the intertwined self-defense claim, Moore's counsel failed to raise defense of property. Whether a jury would have believed Moore is distinct from whether


### 20 Clerk's Papers at 307. 21 id, at 301. 22RCW9A.16.020.
7No. 67294-1-1/8 there was evidence to fulfill the defense criteria. Like Hubert, Moore's counsel's 

### performance was deficientforfailing toadvance this defense.23 The State argues that Moore fails to establish deficient performance because there was no credible evidence to support a defense of property instruction in the first trial. It contends that there was no credible evidence that 

### (1) Moore's use of force was "necessary" (2)the force was used to protect "against a malicious trespass or other malicious interference," and (3) there 

### was a "trespass" or "interference" because the apartment manager invited Storer
to tow the vehicle. This view ofthe record is too narrow. 

### As just discussed above, there was evidence tending to supportthis 

### defense,which entitled Moore to an instruction.24 Because there wassome evidence to support this defense, this argument is not persuasive. The State also contends that the decision ofcounsel in the first trial to advance a self-defense theory and not a defense ofproperty theory was 

### legitimate trialstrategy. We are not persuaded by this argument. As discussed above, the two defenses were intertwined because they


### were based on closely related facts. They were not conflicting or otherwise inconsistent. Even ifself-defense was deemed the better argument, there is no 

### persuasive explanation why the intertwined argument as to defense ofproperty should have been omitted.



### 23 See Hubert. 138Wn. App. at 930. 

### 24 See Dyson. 90 Wn. App. at 438.
8No. 67294-1-1/9
The State further asserts that the RALJ court's determination that counsel
was "unaware" of defense of property was not supported by the record. Whether counsel in the first trial was unaware of the defense is not determinative. What is determinative is that an available defense, supported by evidence in the record,
was not advanced. And the argument that the decision was eithertactical or strategic is not convincing. Prejudice As noted above, to show prejudice, a defendant must prove that but for the deficient performance, there is a reasonable probability that the verdict would 

### have been different.25 A reasonable probability is one sufficientto undermine confidence in the outcome.26 In Hubert, the case discussed above, this court explained how the defense 

### counsel's "failuretodiscoverandadvance the [sole] defense"27 resulted in prejudice in Hubert's trial: 

### The jurywas unaware that if Hubert reasonably believed Wood had capacity to consent, his belief constituted a defense to the charge. Thejurythus had no way to understand the legal significance ofthe evidence supporting the reasonableness of Hubert's beliefthat 

### Wood wasawake and capable ofconsenting tohis advances.1281

25Pirtle. 136Wn.2dat487. 

### 26 State v. Thomas. 109 Wn.2d 222, 226, 743 P.2d 816 (1987).

27 Hubert. 138 Wn. App. at 930. 28 Id. at 932.No. 67294-1-1/10 Here, the deficient performance ofMoore's first trial counsel was also 

### prejudicial, given the State's theory of the case. During closing argument at the first trial,the State argued, without objection, "Even if[Storer] was stealing his car, does this give the defendant a right to hit him or should he have called the 

### police, and saylook, this guy's doing anunlawful tow[?]"29 The Statealso argued, without objection, that Moore could not "claim self-defense for 

### property."30 Counsel'sfailure toobjecttoboth ofthese comments is unexplained. Further, Moore's counsel stated that this case was "notabout [Moore's] car," and whatwas happening with the car "was happening on the 

### periphery."31 Because Moore's counsel inthe first trial failed to argue a defense of 

### propertytheory, the State's argument about Moore's unlawful reaction was not refuted. Thus, likeHubert, thejury in the second trial did not have a way of 

### understanding the legal significance of Moore's beliefthat Storer was "stealing" 

### orunlawfullytowing his car.32 IfMoore's counsel had advanced a defense of property theory, there is a reasonable probability that the outcome of the firsttrial would have been different, assuming thejury believed Moore.



### 29 Clerk's Papers at 324. 30 Id 

### 31 jd at 325. 32 See Hubert. 138 Wn. App. at 932.
10No. 67294-1-1/11 Thus, the RALJ court properly determined that Moore's counsel was 

### "ineffective byfailing to raise, explore, and request instructions on the affirmative 

### defense ofdefense ofproperty" in thefirst trial.33 The State asserts thatthe trial court failed to properly apply the prejudice 

### prong of the Strickland standard. In its decision, the RALJ court explained that "it
was patent ineffectiveassistance ofcounsel not to argue and seek a defense of property instruction under the circumstances and facts presented in this case." In this court's order granting discretionary review, there was an expressed


### concern over the possible use of a "per se testfor ineffectiveassistance." As noted above, to show prejudice, a defendant must prove that but for 

### the deficient performance, there is a reasonable probability that the verdictwould have been different.35 While the RALJ court did notexpressly apply the prejudice 

### prong of the Strickland standard, prejudice was necessarily implied in the ruling. The RALJ court explained that the "failure by counsel to properly raise [the 

### defense ofproperty] affected cross examinationin a fundamental way. . . ." Because self-defense and defense of property were intertwined based on the facts of this case, there was a reasonable probabilitythat ifboth of the defenses had been presented, the outcome would have been different.



### 33 Clerk's Papers at 331-32. 34 id at 332. 35 Pirtle, 136Wn.2dat487. 

### 36 Clerk's Papers at 332. 11No. 67294-1-1/12 The State also argues that Moore is unable to establish prejudice. It contends that Moore remains "unable to explain exactly what questions he would have posed to Mr. Storer, had he been available to testify in the retrial, which could not have been answered by Ms. Robben, the property manager," in the second trial. This argument misses the point. Whether a different witness could have answered the questions Moore would have asked Storer is not determinative. Moore did not have the opportunity for proper cross-examination ofStorer on the unasserted defense of property argument. What Seneca Robben said inthe second trial is not determinative of what occurred in the first trial. In sum, the RALJ court did not err when itdetermined that Moore received ineffective assistance of counsel at the first trial because his counsel failed to 

### raise "defense of property." This determination supports the analysis forthe evidentiary and Confrontation Clause issues. ER 804(b)(1) 

### The State next argues that the RALJ court erroneously concluded that the district court abused its discretion by admitting Storer's former testimony. We disagree. ER 804(b)(1) is a hearsay exception forthe admission of a witness's former testimony when that witness is unavailable. Underthis rule, "former testimony of an unavailable witness is admissible only ifthe party against whom

12No. 67294-1-1/13 

### it is offered 'had an opportunity and similar motive to develop the testimony by
..



### . cross . . . examination' when the witness testified."37 This court reviews a trial court's admission ofevidence for abuse of discretion.38 A trial court abuses its discretion when itexercises its discretion on 

## manifestly unreasonable oruntenable grounds orreasons.39 Here, it is undisputed that Storerwas "unavailable" for the second trial and that Moore had an opportunity and in fact cross-examined Storer at the firsttrial. Thus, the issue is whether Moore had a "similar motive" in both trials. Similar Motive 

### The State argues that Moore had a "similar motive" when he crossexamined Storer inthe first trial as compared to his second trial. We disagree. 

### In considering whether a defendant had a "similarmotive" for purposes of the ER 804analysis, we do notsimply ask "whetherat thetwo proceedings the 

## questionertakes the same sideofthe same issue."40 The courtshould also ask "whetherthe questioner had a substantially similarinterestin asserting that side of the issue."41 For example, "[i]fa fact iscritical to a cause of action at a second proceeding but the same factwas only peripherally related to a differentcause of
37 State v. DeSantiaoo. 149 Wn.2d 402, 411, 68 P.3d 1065 (2003) 

### (alterations in original) (quoting ER 804(b)(1)). 38 Id 39 State v. Finch. 137 Wn.2d 792, 810, 975 P.2d 967 (1999). 

### 40 United States v. DiNapoli. 8 F.3d 909, 912 (2nd Cir. 1993).

13No. 67294-1-1/14 action at a first proceeding, no one would claim that the questioner had a similar motive at both proceedings to show that the fact had 

### been established (ordisproved)."1421 In State v. DeSantiago. the supreme court considered whether the "similar 

### motive" requirement ofER 804(b)(1) was met.43 There, five men werecharged with kidnapping.44 During theirtrial, three key witnesses testified about the 

### abduction.45 Butthejurywasunable to reach averdict.46 Three days before the retrial, the State explained that the three witnesses 

### would nottestify becausethey had moved andwere afraid ofthedefendants.47 The State moved to admit the witnesses' former testimony and the trial court 

### granted this motion.48 Fortheretrial, the State added a new burglary charge.49 On appeal, the defendants argued the trial court abused its discretion in admitting the former testimony because the new charge "produced a new or stronger motive to cross

### examine" thewitnesses.50 The supremecourtacknowledged thatthis issue
42 Id (quoting DiNapoli. 8 F.2d at912). 43 149Wn.2d 402, 413-15, 68 P.3d 1065 (2003). 44 Id at408-09. 45 Id at 407. 

### 46 |d at 408. 

### 47 id at408-09. 48 Id 

### 49jd at 410, 413-14. 50jd at 413. 14No. 67294-1-1/15 raised a close question but determined that the trial court did not abuse its 

### discretion when it admitted theformertestimony.51 The supremecourt explained: Here, the defendants charged with burglary did not have reason to focus on [a witness's] description of damage to the inside ofthe house when they faced only kidnapping charges. However, they did have some motive to discredit those statements because cut phone lines and damage to the door suggested criminal intentions, contrary to the defendants' assertions thattheir 

### interaction with [awitness] wasfriendly.[52] In this explanation, the supreme court recognizes thatwhilethe charges in the 

### two trials changed, thedefense remained the same.53 The defense was thatthe defendants' actions toward thealleged victim were "friendly."54 This defense gave the defendants "some motive" to discredit statements in the first trial 

### regarding the burglary charge, i.e., damagetothealleged victim's home.55 Thus, 

## the courtproperlydetermined thatthe "similarmotive" requirementwas met.56 Here, in contrast, Moore did not have the same defenses in both trials. In the first trial, Moore's counsel only raised self-defense. Inthe second trial, Moore's counsel raised self-defense anddefense of property. As a result, Moore's counsel in the first trial did not have a "similar motive" to cross examine 

### 51 jd at 413, 415. 52 Id at 414-15 (emphasis added). 53 Id. 54 Id 55 Id
56
15No. 67294-1-1/16 

### Storer in both trials, given the different defenses raised in the two trials. Instead, cross-examination focused only on self-defense. In sum, the RALJ court properly determined that the district court abused its discretion when it admitted Storer's former testimony under ER 804(b)(1). 

### The State argues that "the superior court's decision regarding counsel's motive to conduct cross-examination is based upon a misapplication ofthe 

### Strickland standard."57 Butas discussed above, the superiorcourt correctly determined that Moore's counsel was ineffective in the first trial for failing to raise 

### "defense of property." Thus, the only argument the State makes regarding "motive" is not persuasive. CONFRONTATION CLAUSE 

### The State argues that the RALJ court erred when itconcluded that 

### Moore's "rightto confrontation was violated because his attorney in the firsttrial
was ineffective byfailing to raise, explore, and request instructions on the 

### affirmative defense ofdefense ofproperty."58 We reach this question to emphasize the importance of the RALJ court's additional basis for its ruling: the violation ofMoore's right to confrontation underthe SixthAmendment. The Sixth Amendment Confrontation Clause provides that "[i]n all criminal 

### prosecutions, the accused shall enjoy the right... to be confronted with the 

### witnesses againsthim."59 "The confrontation clauseprohibits admission of
57 Briefof Appellant at 31. 58 |d at 22-27; see also Clerk's Paper at 331-32. 59 U.S. Const, amend. VI. 16No. 67294-1-1/17 testimonial statements made out ofcourt by a witness who is unavailable for trial 

### unless there has been a prioropportunityfor cross-examination."60 This court reviews de novo whether a trial court has violated an accused's confrontation 

### rights.61 Here, it is undisputed that Storer's testimony in the first trial was testimonial. It is also undisputed that he was "unavailable" for the second trial. Thus, the issue is whether Moore's opportunity for cross-examination at Storer's 

### trial was"adequatetofulfill thepurposes oftheconfrontation clause."62 Adequacy ofCross-Examination The State argues that Moore had an adequate opportunity to cross

### examine Storer at the first trial.63 It contends that Storer was "subjected to unfettered and properly motivated questioning about the facts underlying the 

### assault."64 We disagree. As noted above, "The confrontation clause prohibits admission of testimonial statements made out ofcourt by a witness who is unavailable for trial



### 60 State v. Mohamed. 132Wn. App. 58, 63, 130P.3d401 (2006): see also Crawford v. Washington. 541 U.S. 36, 54-55, 124 S. Ct. 1354, 158 L Ed. 2d 177 (2004).

### 61 Mohamed. 132Wn. App. at 63-64. 62 id at 65; see also Crawford. 541 U.S. at 57 ("[P]riortrial orpreliminary hearing testimony is admissible only ifthe defendant had an adequate opportunity to cross-examine."). 

### 63 BriefofAppellant at 27. 64 Id.
17No. 67294-1-1/18 

### unless there has been a prioropportunity for cross-examination."65 The Confrontation Clause's "primary interest" is to secure "the right of crossexamination, 'the principal means by which the believability of a witness and the 

### truth ofhis testimony aretested.'"66 This clause guarantees an adequate 

### opportunityfor "full and effective" cross-examination.67 In State v. Mohamed. this court explained that "similarity of motive is a 

### useful and relevanttool" when conducting aConfrontation Clause analysis.68 Here, Moore cross-examined Storer at the first trial, but this examination
was not "full and effective." Itomitted exploration of Moore's defense of property, 

### though Storerwas the only other witness with first-hand knowledge of the events.

65 Mohamed. 132 Wn. App. at 63: see also Crawford. 541 U.S. at 54-55. 

### 66 State v. Foster. 135 Wn.2d 441, 456, 957 P.2d 712 (1998) (internal 

### quotation marks omitted) (quoting Kentucky v. Stincer. 482 U.S. 730, 736, 107 S. Ct. 2658, 96 L. Ed. 2d 631 (1987)). 

### 67 California v. Green. 399 U.S. 149, 158, 90S. Ct. 1930, 26 L. Ed. 2d 489 (1970): see also Davis v. Alaska. 415 U.S. 308, 318, 94 S. Ct. 1105, 39 L. Ed. 2d 

### 347 (1974); 5C Karl B.Tegland, Washington Practice: Evidence Lawand Practice § 1300.13 (2007) ("Prior to Crawford's redefinition of the right to confrontation in 2004, a line of cases held that when the State introduced a declarant's out-of-court statement pursuantto an exception to the hearsay rule, 

### and the declarant was present at trial, the defendant was entitled to full and effective cross-examination of the declarant at trial. The cases defining 'full and 

### effective' in this context may continue to be instructive, at least when the State is introducing testimonial hearsay.") 

### 68 132Wn. App. 58,66, 130 P.3d401 (2006): see also State v. Benn. 161 Wn.2d 256, 265, 165 P.3d 1232 (2007) ("Both the Sixth Amendment's confrontation clause and ER 804(b)(1) bar admission ofprevious testimony of an unavailable witness, unless the defendant had a prior opportunity andsimilar motive to cross-examine the witness.") (emphasis added).
18No. 67294-1-1/19 For these reasons, the RALJ court properly concluded that Moore's right
to confrontation was violated when the district court admitted Storer's former testimony. Moore was not able to fullyand effectively cross-examine Storer regarding defense of property. Further, the State does not argue that any error was harmless beyond a 

### reasonabledoubt.69 Accordingly, weconcludethat the RALJ court did noterr when it reversed and remanded this case. The State argues that "Storerwas subjected to unfettered and properly 

### motivated questioning about the facts underlying the assault," which satisfies the Confrontation Clause.70 While Moore's counsel in the first trial had "unfettered" 

### opportunity to cross-examine Storer in the first trial, the questioning was not 

### properly motivated for the reasons discussed above. Thus, this argument is not persuasive. The State also contends that defense counsel's choice to "pursue one 

### legitimateaffirmative defense over another questionable affirmative defense has 

### no bearing on whethertheConfrontation Clausewas satisfied."71 But, as discussed above, defense counsel's "choice" constituted ineffective assistance of counsel in the first trial. Thus, this ineffective assistance prevented Moore from "fulland effective" cross-examination of Storer during the first trial.

69 See, e.g.. Benn. 161 Wn.2d at 266. 

### 70BriefofAppellantat27. 71 id
19No. 67294-1-1/20 We affirm the RALJ court's reversal and remand for further proceedings. 

# 6&k>T.

WE CONCUR:
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# ^j.

20