Alejandro Martinez-Arias v. State

CourtCourt of Appeals of Georgia
DecidedJuly 14, 2020
DocketA20A1080
StatusPublished

This text of Alejandro Martinez-Arias v. State (Alejandro Martinez-Arias v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alejandro Martinez-Arias v. State, (Ga. Ct. App. 2020).

Opinion

SECOND DIVISION MILLER, P. J., MERCIER and COOMER, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

DEADLINES ARE NO LONGER TOLLED IN THIS COURT. ALL FILINGS MUST BE SUBMITTED WITHIN THE TIMES SET BY OUR COURT RULES.

July 14, 2020

In the Court of Appeals of Georgia A20A1080. MARTINEZ-ARIAS v. THE STATE.

MERCIER, Judge.

Following a jury trial, Alejandro Martinez-Arias was convicted of child

molestation, aggravated child molestation, and aggravated sexual battery. He appeals

the denial of his motion for new trial, arguing that the trial court erred in admitting

certain testimony and that he received ineffective assistance of counsel. We affirm.

Viewed in the light most favorable to the jury’s verdict, the evidence shows

that the victim and two of her brothers began living with their aunt and Martinez-

Arias, the aunt’s boyfriend, when the victim was nine years old. On multiple

occasions, Martinez-Arias touched the victim’s chest when she was alone in the

house with him after school. He also entered her bedroom at night, touched her vagina with his fingers and mouth, and put her hand on his penis. The touchings

occurred almost every day and continued until she was approximately 12 years old.

The victim did not immediately report the abuse because she did not know

whether anyone would believe her, and she was afraid of what would happen if she

told. Eventually, however, she confided in one of her brothers, who informed their

grandmother that they needed to come live with her. Her brother also gave the victim

a cell phone to record her next encounter with Martinez-Arias. The victim hid the

phone in her bed and started recording when she heard Martinez-Arias entering her

room that night. The victim and her brothers left the home a short time later and were

picked up by their grandmother. They reported the abuse to the police and gave

investigators the cell phone with the recording.

The jury found Martinez-Arias guilty of child molestation, aggravated child

molestation, and aggravated sexual battery. The trial court denied his motion for new

trial, and this appeal followed.

1. Martinez-Arias claims that the trial court erred in admitting testimony from

the victim’s school counselor that, in his view, was irrelevant and encouraged jurors

to consider ethnic stereotypes. He further argues that the counselor’s testimony

2 included expert opinions that the State failed to properly disclose to him. See OCGA

§ 17-16-4 (a) (4) (setting forth requirements for disclosure of expert opinions).

(a) In addition to describing her interactions with the victim, the school

counselor offered testimony about Latino culture. The evidence shows that the

victim’s family is originally from Mexico, and the victim’s father lived there. Noting

her own Latino heritage and professional experience working with at-risk Latino

youth and Latino children who had been exposed to sexual abuse, the counselor

began describing what she termed the “machismo” and “collectivistic family” nature

of the Latino culture. Martinez-Arias objected, asserting that the testimony contained

hearsay, was irrelevant, and was based on expert opinions that had not been

previously disclosed to him. The prosecutor responded that she had “provided the

foundation for [the counselor] to give personal experience of attitudes she ha[d]

witnessed in the Latino culture.” The trial court sustained the hearsay objection, but

otherwise permitted the testimony.

The prosecutor asked the witness to describe attitudes she had noticed “with

the Latino culture and sexual abuse.” In response, the school counselor testified about

the “machismo culture,” in which females “are supposed to be submissive to” the

male head-of-household. Martinez-Arias again objected on relevance grounds,

3 asserting that the testimony was conjecture that did not “bear on the facts” of the case.

The prosecutor countered that Martinez-Arias had elicited cultural-oriented testimony

from the State’s witnesses on cross-examination, including that the victim was

expected to take part in “older traditional female roles” at home, such as helping her

aunt with cleaning and cooking.

The trial court overruled the relevance objection, concluding that “the jury can

use the evidence for whatever value, if any, the jury finds in this case.” Thereafter,

the counselor testified about Latino cultural norms she had observed in cases of child

sexual abuse, specifically, that Latino girls reporting such abuse experience guilt,

shame, a lack of family support, and difficulty making disclosures. According to the

counselor, these victims feel that “it’s the girl’s fault for opening her legs and the

boys are just supposed to be that way, they just have urges.” She further stated: “[T]he

Mexican culture, in particular, it’s taboo – sexual education is a taboo topic among

Latinos and a lot more in the Mexican structure, because it’s based on religious

foundations[.]”

Martinez-Arias argues that the trial court erred in admitting this testimony

because “cultural norms around gender and sexuality are not relevant to whether a

4 crime occurred.” Because the evidence tended to explain the victim’s behavior, we

disagree.

“[T]he term ‘relevant evidence’ means evidence having any tendency to make

the existence of any fact that is of consequence to the determination of the action

more probable or less probable than it would be without the evidence.” OCGA § 24-

4-401. A trial court has broad discretion in determining evidence admissibility. See

Cherry v. State, 345 Ga. App. 409, 412 (2) (813 SE2d 408) (2018). And under

Georgia law,

evidence which in connection with other evidence tends, even slightly, to prove, explain, or illustrate a fact is probative and relevant. Doubt as to relevancy should be resolved in favor of admission and against exclusion, with the evidence’s weight left to the jury.

Id. (citation and punctuation omitted).

According to Martinez-Arias, the counselor’s testimony proved nothing with

respect to whether he molested the victim. But the testimony provided context for the

several-year delay in the victim’s outcry, a relevant issue given “the defense’s theory

that the allegations of abuse were fabricated.” Alford v. State, 320 Ga. App. 523, 527

(2) (a) (738 SE2d 124) (2013). Although Martinez-Arias claims that the evidence

encouraged “a verdict that took [his] ethnicity into account,” the trial court was

5 authorized to conclude that the testimony related to the victim’s fear and failure to

immediately disclose the abuse, rather than Martinez-Arias’s ethnicity. Under these

circumstances, the trial court acted within its discretion in deeming the counselor’s

testimony relevant.1 See id. at 528 (2) (b); see also Nguyen v. State, 271 Ga. 475, 476-

577 (2) (520 SE2d 907) (1999) (affirming trial court’s decision to exclude cultural

background evidence, but noting that such evidence may be relevant in certain cases).

(b) Moreover, the trial court did not err in finding that the counselor’s

testimony was admissible as lay opinion evidence, rather than expert testimony.

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Related

Nguyen v. State
520 S.E.2d 907 (Supreme Court of Georgia, 1999)
United States v. Woodrow Andrew Clark
710 F. App'x 418 (Eleventh Circuit, 2017)
Davis v. State
805 S.E.2d 859 (Supreme Court of Georgia, 2017)
Cherry v. State
813 S.E.2d 408 (Court of Appeals of Georgia, 2018)
Priester v. State
828 S.E.2d 439 (Court of Appeals of Georgia, 2019)
Slan v. State
730 S.E.2d 565 (Court of Appeals of Georgia, 2012)
Alford v. State
738 S.E.2d 124 (Court of Appeals of Georgia, 2013)
Pitts v. State
747 S.E.2d 699 (Court of Appeals of Georgia, 2013)
Bullard v. State
307 Ga. 482 (Supreme Court of Georgia, 2019)
Gaston v. State
837 S.E.2d 808 (Supreme Court of Georgia, 2020)

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Alejandro Martinez-Arias v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alejandro-martinez-arias-v-state-gactapp-2020.