Washington v. People
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The case revolves around Joseph Wayne Washington, who was charged with multiple crimes including murder, drug possession, witness tampering, violation of a protection order, and solicitation of murder. Washington argued that these charges should not have been tried together, citing a previous case, Norman v. People, which he believed established a rule of automatic reversal for improper joinder of charges.
The case was first tried in a lower court where Washington's motion to sever the charges into four separate cases was denied. The court ruled that all seventeen charges were interconnected and part of the same incident. The case proceeded to trial, and Washington was found guilty of second degree murder, ten drug possession counts, violation of a protection order, and witness tampering. He was acquitted of first degree murder, one of the drug possession counts, and the murder solicitation charges.
Washington appealed, arguing that his convictions should be reversed due to prejudicial misjoinder under Rule 8(a)(2). The court of appeals affirmed Washington’s conviction, concluding that misjoinder is not a structural error and requires the same harmless-error review that applies to other trial errors.
The Supreme Court of the State of Colorado affirmed the decision of the court of appeals. The court clarified that the previous case, Norman v. People, did not create a rule of automatic reversal for improper joinder of charges. Instead, the court held that harmless-error review applies to misjoinder. The court concluded that if there was any error in joining the various charges in Washington’s case, that error was harmless.
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