State v. Hayes
| Decision Date | 20 March 2020 |
| Docket Number | Docket No. 47324 |
| Citation | 166 Idaho 646,462 P.3d 1110 |
| Court | Idaho Supreme Court |
| Parties | STATE of Idaho, Plaintiff-Respondent, v. Michael Theron HAYES, Defendant-Appellant. |
Eric D. Fredericksen, State Appellate Public Defender, Boise, for appellant. Ben P. McGreevy argued.
Lawrence G. Wasden, Idaho Attorney General, Boise, for respondent. Kenneth K. Jorgensen argued.
Michael Theron Hayes appeals his judgment of conviction from Ada County district court. A jury convicted Hayes of felony battery on a correctional officer. Hayes appealed his judgment of conviction on three grounds: (1) the district court erred by failing to issue subpoenas for two medical professionals; (2) the district court abused its discretion by allowing the State to inquire into prior instances of Hayes' conduct towards correctional officers; and (3) the district court abused its discretion by denying Hayes' motion for a new trial. The Court of Appeals reversed the district court's order denying Hayes' requests for subpoenas, and held that the district court abused its discretion by allowing the State to inquire into prior instances of Hayes' conduct. Accordingly, the Court of Appeals vacated the district court's judgment of conviction and remanded the case for a new trial. This Court granted the State's timely petition for review. For the reasons stated below, we affirm Hayes' judgment of conviction.
Hayes is an inmate housed at the Idaho Maximum Security Institution (IMSI). On November 10, 2015, Correctional Officer Rachel Nettles escorted Hayes to an infraction hearing for alleged misconduct at IMSI. During the infraction hearing, Hayes allegedly became aggressive and non-compliant with the correctional officers. After attempts to calm Hayes failed, Nettles and Correctional Officer Charles Johannessen attempted to secure Hayes against a nearby wall. Hayes allegedly resisted, kicking Nettles in the shin and grabbing Johannessen in the groin. The State charged Hayes with two counts of felony battery on a correctional officer pursuant to Idaho Code sections 18-915(2), 18-901, and 18-903. The State also filed a persistent violator sentencing enhancement pursuant to Idaho Code section 19-2514.
Hayes pleaded not guilty to the battery charges, and chose to represent himself. When Hayes chose to represent himself, the district court specifically advised Hayes about the advantages of having counsel for discovery and witness investigation. Nevertheless, Hayes was staunch in his desire to represent himself. After the district court ruled that Hayes would represent himself, it appointed Ada County public defender Craig A. Steveley as Hayes' standby counsel.
Prior to trial, Hayes requested subpoenas for Dr. April Dawson and nurse Kevin Kaae, who were both contracted to provide care to inmates at IMSI through Corizon Correctional Healthcare. In support of his subpoena requests, Hayes asserted that Dawson and Kaae would testify at trial to the injuries he allegedly received from the correctional officers' use of force in the November 10, 2015 altercation. Specifically, Hayes asserted that Dawson and Kaae would testify that: (1) after the November 10, 2015 altercation, multiple ultrasounds revealed blood in Hayes' urine; (2) blood was visible in Hayes' urine to the naked eye after the November 10, 2015 altercation; (3) Hayes' subsequent medical tests reveal that no disease or kidney stones
caused blood to appear in Hayes' urine; and (4) Hayes' subsequent medical tests demonstrate the blood in his urine was caused by the November 10, 2015 altercation with the correctional officers.
At a pretrial hearing, the district court denied Hayes' subpoena requests on two grounds. First, the district court ruled that the subpoena requests were untimely. Second, the district court concluded that, even considering the merits of Hayes' subpoena requests, the district court did Later in the same hearing, Hayes requested to be represented by counsel. Hayes requested counsel just three days before his trial was scheduled to begin. The district court subsequently appointed Steveley—who was previously serving as standby counsel—to represent him. As a result, Hayes' trial date was pushed back for two months so that Steveley could prepare a defense.
Prior to the district court's denial of Hayes' subpoena requests, the State filed a motion in limine seeking to prevent Hayes from asking the correctional officers any questions regarding the Idaho Department of Correction's (IDOC) guidelines for disciplinary and infraction hearings. The State argued that questions regarding IDOC's guidelines for conducting infraction hearings were irrelevant to whether Hayes committed battery upon the two correctional officers. The district court agreed that IDOC's guidelines would not be relevant to the question of battery, and granted the State's motion in limine.
At Hayes' jury trial, he testified on his own behalf. On direct examination, he testified that he was the victim of the November 10, 2015 altercation. Hayes alleged that, immediately after the November 10, 2015 infraction hearing, he was battered by the correctional officers without provocation. Hayes maintained a position of innocence, asserting that he never battered the correctional officers. Hayes further testified that because of the correctional officers' battery, he sustained injuries to his back, shoulder, wrists, and hip. Hayes also testified that the injuries he sustained caused him to urinate blood. Hayes did not make a self-defense claim.
On cross-examination, the State inquired about Hayes' conduct toward other correctional officers and inmates at IMSI. Hayes testified that he was always respectful towards other inmates and correctional officers. Outside the presence of the jury, the State requested that it be allowed to question Hayes on his prior instances of conduct towards inmates and correctional officers. Specifically, the State proffered approximately ten instances where Hayes threatened, verbally abused, and disrespected other inmates and correctional officers. Hayes objected to the line of questioning, arguing that the testimony would be unfairly prejudicial under Idaho Rule of Evidence 403 and improper character evidence under Rule 404(b). The district court asked both parties which rules of evidence applied. The State argued that the evidence was relevant, and that the evidence was admissible under Rule 608(b) as evidence of Hayes' character for untruthfulness. Hayes argued that Rules 403, 404(b), and 608(b) all applied, making the testimony inadmissible.
The district court found that the evidence was relevant and not unfairly prejudicial, and concluded that the testimony was relevant to Hayes' character for truthfulness under Rule 608(b). Thus, the district court allowed the State to inquire into Hayes' prior instances of conduct. On the witness stand, Hayes denied that any of these prior instances of conduct occurred. Later in the trial, the district court issued a limiting instruction to the jury regarding Hayes' testimony on cross-examination. The limiting instruction informed the jury that this testimony was admitted for the limited purpose of Hayes' credibility, and that the evidence should not be considered for any other purpose.
After deliberations, the jury found Hayes guilty of one count of battery—kicking officer Nettles in the shin during the November 10, 2015 altercation. Seconds after the clerk delivered the verdict, Hayes interrupted the district court proceeding, and announced, "Craig Steveley is fired and the defendant is now in pro se representation." Hayes was subsequently removed from the courtroom for his behavior, and ultimately was allowed to discharge Steveley and proceed pro se. The State later voluntarily dismissed the persistent violator sentencing enhancement.
Months after the verdict, but prior to sentencing, Hayes again changed his mind on pro se representation and moved for appointment of conflict counsel. Hayes, through conflict counsel, filed a motion for a new trial. In support of the motion, Hayes argued that the district court erred in granting the State's motion in limine to prohibit any questions related to IDOC's guidelines for conducting infraction hearings. Hayes asserted that the guidelines were relevant to whether the correctional officers had a "motive to lie" about their behavior during the altercation, and whether they complied with such guidelines. The district court subsequently denied Hayes' motion for a new trial. In denying the motion, the district court found that questions regarding IDOC's infraction hearing guidelines were irrelevant to the issues at trial. Further, the district court found that even if the guidelines were relevant, the testimony would be inadmissible as "a waste of time, confusing the issues, and misleading the jury" under I.R.E. 403.
The district court imposed a fixed determinate sentence of two and one half-years to be served consecutively with the sentence Hayes is currently serving. Hayes timely appealed the judgment of conviction. On appeal, the Court of Appeals reversed the district court's order denying Hayes' requests for subpoenas, and held that the district court abused its discretion by allowing the State to inquire into prior instances of Hayes' conduct. Accordingly, the Court of Appeals vacated the judgment of conviction and remanded the case for a new trial. The State filed a timely petition for review. This Court subsequently granted that petition. We affirm the judgment of conviction.
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State v. Hayes
...166 Idaho 646462 P.3d 1110STATE of Idaho, Plaintiff-Respondent,v.Michael Theron HAYES, Defendant-Appellant.Docket No. 47324Supreme Court of Idaho, Boise, December 2019 Term.Opinion Filed: March 20, 2020Petition for Rehearing Denied: May 26, 2020Eric D. Fredericksen, State Appellate Public D......