Ronald J. JACKSON, Appellant,
UNITED STATES, Appellee.
March 13, 2019
[Copyrighted Material Omitted]
from the Superior Court of the District of Columbia
(CF3-15862-15) (Hon. Marisa J. Demeo, Trial Judge)
A. Daniels for appellant.
Hansford, Assistant United States Attorney, with whom Jessie
K. Liu, United States Attorney, and Elizabeth Trosman,
Michael P. McCarthy, and Ryan Creighton, Assistant United
States Attorneys, were on the brief, for appellee.
Fisher and Beckwith, Associate Judges, and Ferren, Senior
found appellant Ronald Jackson guilty of assault with a
dangerous weapon. The sole question before this court is
whether the trial court abused its discretion by admitting
evidence that appellant used PCP eighteen hours before the
attack without any accompanying expert testimony enabling the
jury to evaluate whether Jackson was under the influence of
the drug at the time of the assault. We reverse and remand
for a new trial.
I. Factual Background
Appellant Ronald Jackson and Desmon Beasley had been best
friends for over forty years. In 2014, Jackson moved into
Beasleys apartment. At that time, Beasley weighed over 600
pounds and, as a result, had limited mobility. Jackson paid
Beasley a small amount in rent and assisted Beasley with
November 2015, the situation between Beasley and Jackson had
changed, and Beasley wanted Jackson to move out. Beasley had
lost a considerable amount of weight and was better able to
move around. He began to pursue a romantic relationship with
his friend, Erika Williams, and found it difficult to do so
with Jackson in the apartment. Additionally, Beasley was
frustrated by Jacksons inability to maintain a steady job
and had difficulty supporting both himself and Jackson on his
Social Security income.
Tensions between Jackson and Beasley came to a head on
November 13, 2015. That morning, Beasley told Jackson to
leave the apartment and offered him money for a Metro fare.
Beasley heard Jackson leave, and then went back to sleep in
the bedroom with Williams. Later that afternoon, Williams
woke up and asked Beasley to escort her to the bathroom. From
the hallway, Beasley saw Jackson sitting on the couch in the
living room, shucking clams and eating ice cream.
According to the evidence at trial, Beasley approached
Jackson and demanded multiple times that he leave the
apartment. Jackson did not respond to Beasley and, instead,
stared at the television with a blank face and glassy eyes.
Beasley grew upset that Jackson was not responding to him.
Although Beasley and Jackson had never physically fought
during their forty-year friendship, Beasley struck Jackson
hard on the head. During the ensuing scuffle, Jackson picked
up the knife he was using to shuck clams and swung it at
Beasleys face, striking him in the eye. By all accounts, the
attack was out of character for Jackson, who is normally a
peaceful person. The attack left Beasley blind in his left
II. Relevant Trial Testimony
A. Evidence of Drug Use
to trial, the government moved in limine to admit evidence
that Jackson used phencyclidine (PCP) on November 12, 2015,
the night before the fight. The government contended that
such evidence provided important context that would serve to
explain Jacksons odd behavior, why Beasley wanted Jackson to
leave the apartment, and why Beasley was in the living room
when he was assaulted. Jackson opposed the motion, arguing
that any evidence of PCP use was evidence of other crimes or
bad acts which was unfairly prejudicial.
Marisa Demeo ruled the evidence admissible. Citing cases
which we discuss below, the court found that such testimony
would provide context and serve to explain the witnesses
observations, beliefs, and behaviors. The court determined
that there was a close temporal relationship ...