State v. Grunwald
| Decision Date | 02 July 2020 |
| Docket Number | No. 20180459,20180459 |
| Citation | 478 P.3d 1 |
| Parties | STATE of Utah, Respondent, v. Meagan GRUNWALD, Petitioner. |
| Court | Utah Supreme Court |
On Certiorari to the Utah Court of Appeals
Introduction
¶1 Meagan Grunwald was convicted as an accomplice to the crime of aggravated murder. But the jury instruction that provided the basis for her conviction contained three errors: (1) it impermissibly permitted conviction based on a finding of recklessness, a less culpable mental state than is required by statute, (2) it impermissibly permitted conviction based on intentional aid that was not directly connected to the murder, and (3) it impermissibly permitted conviction based on a finding that Ms. Grunwald knew that the principal actor's conduct was reasonably certain to result in aggravated murder, rather than on the finding that she knowingly committed the actus reus to help the principal actor in committing the murder. We must determine whether any of these errors, or a combination of them, caused a reasonable probability of an unfair conviction. In other words, we must determine whether, in the absence of these errors, there is a reasonable probability the jury would have arrived at a different result.
¶2 The court of appeals considered this question and determined there was no such probability. Accordingly, that court affirmed Ms. Grunwald's conviction. Now Ms. Grunwald asks us to reverse the decision of the court of appeals because, in her view, the court failed to properly consider all of the evidence presented to the jury and misconstrued some of the legal requirements of accomplice liability. Because it is reasonably probable that the jury would not have convicted Ms. Grunwald of aggravated murder absent the jury instruction errors, we reverse her conviction and remand for a new trial with correct jury instructions.1
¶3 Jose Angel Garcia Juaregi (Mr. Garcia) shot and killed a police officer through the back window of his girlfriend's pickup truck. Some of the facts surrounding this murder are undisputed, while others are hotly contested and underlie the key issue on appeal.
¶4 It is undisputed that at the time of the murder Mr. Garcia and his girlfriend, Meagan Grunwald, were parked on the side of a road with their hazard lights flashing, and that Sergeant Cory Wride, the victim-police officer, had pulled up behind them to perform a "motorist assist." During the motorist assist, Sergeant Wride first approached the driver-side door to speak to Ms. Grunwald, who was driving, and asked her if she was okay. Although she was crying and her face was red, she told Sergeant Wride that she was fine. Sergeant Wride then returned to his car to verify Ms. Grunwald's and Mr. Garcia's identities through a search of a police database. But Mr. Garcia had provided a false name and birthdate because a warrant had been issued for his arrest, so Sergeant Wride's search did not yield any results.
¶5 Video footage from Sergeant Wride's dashboard camera reveals what happened next. About ten minutes into the motorist assist, Sergeant Wride exited his car and approached the passenger-side window to speak to Mr. Garcia. At the window, Sergeant Wride asked Mr. Garcia if he had provided a false name, and Mr. Garcia admitted that he had. Mr. Garcia then provided another false name, and Sergeant Wride returned to his car to run the second false name through the police database.
¶6 Although the heavy tint on the truck's back window prevented the dashboard camera from recording what was taking place inside the truck, footage does show that about a minute after Sergeant Wride returned to his vehicle, the truck's brake lights flashed on and the lower-rear lights flickered, indicating a gear shift. One minute and a half later, the rear-passenger side window popped open about an inch. Just over one minute after that, the truck lurched forward slightly. And roughly one minute later, the truck's center, rear window slid open and Mr. Garcia fired seven shots at Sergeant Wride in quick succession. After the fifth shot, Ms. Grunwald began pulling onto the road. Mr. Garcia fired the final two shots as she drove away. The entire event—from the time Sergeant Wride spotted Ms. Grunwald's truck parked on the side of the road to the moment the truck drove away after the shooting—took roughly eighteen minutes, the last four of which involved Ms. Grunwald holding her foot on the brake and driving away after the shots had been fired.
¶7 After an extended police chase, Mr. Garcia was shot and killed, and Ms. Grunwald was arrested. Ms. Grunwald was charged as an accomplice in Sergeant Wride's murder, as well as in a number of other crimes that are not at issue in this appeal. A trial followed.
¶8 At trial, the jury was shown the dash-cam footage multiple times. Both parties agree the dash-cam footage accurately depicts the crime in this case. But as to the details of what was taking place inside the truck immediately before Mr. Garcia began shooting, the jury heard two very different stories.
¶9 Ms. Grunwald raised "compulsion" as an affirmative defense at trial. Under the doctrine of compulsion, people are not guilty of a crime if they were coerced, through threat or force, to commit the crime. In support of her compulsion defense, Ms. Grunwald's attorney painted Mr. Garcia as "the ultimate predator and exploiter" and a "master manipulator" and Ms. Grunwald as a scared, impressionable young girl who became increasingly intimidated by Mr. Garcia's growing anger and agitation. According to Ms. Grunwald, while Sergeant Wride was searching Mr. Garcia's false name, Mr. Garcia put a gun to her head and threatened her and her family. He then demanded that she put her foot on the brake, and, after she complied with this demand, he shifted the truck into drive. Finally, Ms. Grunwald testified that she began driving only after Mr. Garcia yelled "go, go, go" at her. So, based on this version of the story, Ms. Grunwald argues that anything she may have done to assist Mr. Garcia in murdering Sergeant Wride was coerced.
¶10 But even though Ms. Grunwald argued she was coerced into acting, she never admitted she intended for Mr. Garcia to kill Sergeant Wride, nor that she knew he would do so. Instead, she testified she did not know Mr. Garcia intended to kill Sergeant Wride, and that, even after Mr. Garcia had shot his gun, she assumed he had merely attempted to disable the police car. Ms. Grunwald did admit, however, that she twice heard Mr. Garcia say that he was going to "buck [Sergeant Wride] in the fucking head." But she testified that she did not know what this statement meant and that Mr. Garcia refused to clarify his meaning when she asked him to do so.2 So even though Ms. Grunwald admits she held her foot on the brake for approximately four and a half minutes before Mr. Garcia began shooting, and that at some point during that time Mr. Garcia stated he was going to "buck" Sergeant Wride in the head, she claims she did not intend for Mr. Garcia to kill him or know that he would do so.
¶11 The State, on the other hand, described Ms. Grunwald as a desperate lover who would not allow anything "to get in her way or come between her and her man." According to the State, upon learning that Mr. Garcia had a "Board of Pardons warrant out," Ms. Grunwald felt "her world crumbling down" because she could no longer be with Mr. Garcia if he were arrested. For this reason, the State argued, she viewed Sergeant Wride as "a threat to her[self] and her future." The State argued that, because of this fear, Ms. Grunwald and Mr. Garcia formed a plan, and that consistent with that plan, Ms. Grunwald intentionally aided in Sergeant Wride's murder. According to the State, she did this by placing her foot on the brake, shifting into gear, waiting with her foot on the brake in preparation for their escape, and acting as a lookout so that Mr. Garcia could open fire when no other cars were driving by.
¶12 After both sides presented their versions of the story at trial, the jury returned a guilty verdict. Ms. Grunwald appealed to the court of appeals. On appeal, she argued that her trial counsel was ineffective for failing to object to three errors in the jury instruction regarding accomplice liability. The court of appeals agreed that the jury instructions erroneously (1) included "recklessness" as a mental state upon which criminal liability could be found;3 (2) allowed the jury to convict Ms. Grunwald based on intentional aid that was not directly connected to the murder;4 and (3) allowed the jury to convict Ms. Grunwald based on knowledge that Mr. Garcia's actions were reasonably certain to result in the aggravated murder, rather than on knowledge that her own actions were reasonably certain to do so.5 The court of appeals also concluded that the performance of Ms. Grunwald's trial counsel was deficient because he did not object to these errors in the jury instructions.
¶13 But the court of appeals determined that those errors were not prejudicial, because the evidence demonstrated that Ms. Grunwald intentionally aided Mr. Garcia to commit those crimes and, because the jury rejected her "compulsion" theory, there was not a reasonable probability of a more favorable outcome absent the errors.
¶14 Ms. Grunwald requested certiorari review of this determination, which we granted.
We have jurisdiction pursuant to Utah Code section 78A-3-102(3)(a).
¶15 We granted certiorari to review whether the court of appeals erred in concluding that Ms. Grunwald's trial counsel's deficient performance did not result in prejudice. On certiorari, "we review the court of appeals’ decision for correctness."6
¶16 Ms. Grunwald argues her aggravated murder conviction should be overturned because her trial counsel was ineffective for failing to object to multiple errors in the relevant jury instruction. The jury instruction...
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