The State of Washington v. Alberto Perez-Valdez (Washington 2011)

Summary

The Washington Supreme Court affirmed the conviction of Alberto Perez-Valdez, holding that the trial court did not abuse its discretion in excluding the arson evidence, in refusing to grant a mistrial after a witness offered an improper opinion, and in barring argument on the defendant’s general moral character. The court applied an abuse‑of‑discretion standard to each evidentiary ruling and found the trial judge’s decisions reasonable. Justice Wiggins dissented, arguing that the exclusion of the arson evidence was erroneous and prejudicial.

Holding

Whether the trial court erred in excluding evidence of the victims' alleged arson to show motive to fabricate accusations. The trial court did not abuse its discretion in excluding the arson evidence; the evidence was deemed collateral and its prejudicial effect substantially outweighed its probative value.

Whether the trial court erred in refusing to declare a mistrial after a witness offered an opinion on the victims' credibility. The trial court did not abuse its discretion in denying a mistrial; the improper statement was curatively instructed to be disregarded and was cumulative of other testimony.

Whether the trial court erred in preventing the defense from referencing the defendant's general moral character evidence in closing argument. The trial court did not err; the general reputation for good moral character was not a pertinent trait to the specific crime and therefore could not be argued about after being deemed inadmissible.

Summary

Holding

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