State v. Stuart

N. PATRICK CROOKS, J.

(dissenting).

¶ 88. I strongly disagree with the majority that the petitioner, Paul J. Stuart, is entitled to a new trial. In order to arrive at that holding, the majority has to dismiss the consistent testimony of five witnesses, each one having testified at trial that Paul Stuart admitted that he killed Gary Reagles. Although I agree that the admission of his brother John Stuart's preliminary hearing testimony violated the petitioner's right to confrontation under Crawford v. Washington, 541 U.S. 36, 124 S. Ct. *6931354 (2004), I conclude that the error under the circumstances in this case was clearly harmless.

¶ 89. "The hallmark of reliability is the consistency of facts and details." United States v. Zehm, 217 F.3d 506, 514 (7th Cir. 2000). Here, five prosecution witnesses, in addition to John, were consistent in their testimony that Paul Stuart admitted to shooting Gary Reagles. One of the most notable witnesses to testify against Stuart at trial was Arthur Parramoure. He accompanied Stuart on a trip to Arizona, which took place a few days after the death of Reagles. He testified that Stuart had decided, on the spur of the moment, that they should leave early on the trip. Parramoure stated that during this trip, Stuart admitted to shooting Reagles, because Reagles could not pay for a gun Stuart had sold him. Stuart admitted during his testimony at trial, that he had confessed to Parramoure, but claimed that he did so in order to frighten Parramoure.

¶ 90. Michael Schultz also testified at trial that Stuart admitted to shooting Reagles. The night after the shooting, Schultz encountered Stuart in a bar and overheard Stuart admit that he had killed Reagles. Schultz stated that he saw Stuart with Reagles in the same bar on the night of the shooting.

¶ 91. David Small testified at trial that Stuart talked about the shooting while the two men shared a cellblock. Stuart told Small that he was in jail for murder, and that he had shot a man in the chest with a .9 millimeter gun. Stuart talked about the gunpowder found on the victim's hands and by his feet, and then said that he had made Reagles' death look like a suicide.

¶ 92. Benjamin Woody also shared a cellblock with Stuart. He too testified at the trial that Stuart stated that the killing of Reagles had been initially ruled a suicide. Stuart commented to Woody about the *694lack of physical evidence that the State had against him. Stuart then stated that he shot Reagles, and that he would do it again.

¶ 93. Finally, Damian Simpson testified at the trial that while Simpson shared a cellblock with Stuart, Stuart admitted to shooting Reagles. Simpson overheard another inmate ask Stuart whether he had shot the man he was in jail for murdering. Stuart replied that he killed him, and that he would do it again.

¶ 94. The majority relies on the harmless error test outlined in Chapman v. California, 386 U.S. 18 (1967), in order to hold that the Crawford violation was not harmless. There, the United States Supreme Court held that "before a federal constitutional error can be held harmless, the court must be able to declare a belief that it was harmless beyond a reasonable doubt." Id. at 24.1 am satisfied that the alternative wording in Neder v. United States, 527 U.S. 1, 2-3 (1999), State v. Weed, 2003 WI 85, ¶ 29, 263 Wis. 2d 434, 666 N.W.2d 485, and State v. Harvey, 2002 WI 93, ¶ 48, n. 14, 254 Wis. 2d 442, 647 N.W.2d 189, sets forth the applicable test. Under either test, however, the error here was harmless.

¶ 95. In attempting to apply the Chapman test, the majority undertakes a lengthy analysis involving factors such as the frequency of the error, the importance of the erroneously admitted evidence, the presence or absence of evidence corroborating or contradicting the erroneously admitted evidence, whether the erroneously admitted evidence duplicates untainted evidence, the nature of the defense, the nature of the State's case, and the overall strength of the State's case. Majority op., ¶¶ 41, 43-58. As noted previously, both this court and the United States Supreme Court have analyzed harmless error by utilizing a more recent *695alternative test. See Neder, 527 U.S. 1; Weed, 263 Wis. 2d 434; and Harvey, 254 Wis. 2d 442. Rather than undertake the lengthy approach of the majority, this court should consider only the error's effect on the jury verdict in light of the fact that five additional witnesses provided testimony, consistent with the testimony of John Stuart, that Paul Stuart admitted his guilt to them. If "it appears 'beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained,'" then the error was harmless. Weed, 263 Wis. 2d 434, ¶ 29 (citation omitted). In order to hold that an error was harmless, a court must be able to conclude " 'beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error.'" Id.; see also Neder, 527 U.S. at 18. I am satisfied that whichever test is applied that the facts of this case establish that the Crawford confrontation error was harmless, given the overwhelming evidence of Stuart's guilt with or without his brother John's testimony.

¶ 96. The testimony of the five additional witnesses was persuasive and consistent with John's preliminary hearing testimony that Paul Stuart admitted killing Reagles. John's testimony was, in effect, "frosting on the cake." It was nice to have, but not necessary to establish that Paul Stuart killed Gary Reagles.

¶ 97. The majority attempts to inflate the importance of John's testimony and attempts to minimize the importance of Arthur Parramoure's testimony, as well as the testimony of the other prosecution witnesses. The record reflects that the jury requested that Parramoure's testimony, along with the testimony of John, be read back to them. The jury rendered a verdict of guilty soon after the reading was completed. This time sequence clearly demonstrates that the jury found *696Parramoure's testimony material, persuasive, and consistent with the other witnesses' testimony.

¶ 98. The Crawford violation was harmless error under Weed, Neder, Harvey, and Chapman. Even without John's testimony, the State presented an overwhelming case in regard to Paul Stuart's guilt. It appears clear that the jury relied on the consistent testimony of the five additional witnesses, and placed special importance on Parramoure's testimony. I have no difficulty concluding " 'beyond a reasonable doubt that a rational jury would have found the defendant guilty absent the error.'" Weed, 263 Wis. 2d 434, ¶ 29 (citation omitted). Therefore, I conclude that the Crawford confrontation error was harmless, and that the petitioner, Paul Stuart, is not entitled to a new trial.

¶ 99. For the above stated reasons, I respectfully dissent.

¶ 100. I am authorized to state that Justices JON P WILCOX and PATIENCE DRAKE ROGGENSACK join this dissent.