Guillermo Martinez-Gaspar v. State

CourtCourt of Appeals of Georgia
DecidedApril 17, 2025
DocketA25A0667
StatusPublished

This text of Guillermo Martinez-Gaspar v. State (Guillermo Martinez-Gaspar 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
Guillermo Martinez-Gaspar v. State, (Ga. Ct. App. 2025).

Opinion

FIFTH DIVISION MCFADDEN, P. J., HODGES and PIPKIN, 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

April 17, 2025

In the Court of Appeals of Georgia A25A0667. MARTINEZ-GASPAR v. THE STATE.

MCFADDEN, Presiding Judge.

After a jury trial, Guillermo Martinez-Gaspar was convicted of rape, OCGA §

16-6-1 (a) (1), and furnishing alcohol to a person under 21 years of age. OCGA § 3-3-23

(a) (1). The trial court sentenced him to serve 25 years in prison followed by life on

probation. Martinez-Gaspar appeals the denial of his motion for new trial. He argues

that the trial court erred in refusing to admit into evidence a statement the victim’s

mother made on the call to 911 and a statement included in a police report. But the

statements are hearsay, and the trial court did not abuse his discretion in excluding

them. So we affirm.

1. Trial evidence The trial evidence showed that the victim, who was 18 years old at the time of

the incident, lived with her parents. Martinez-Gaspar lived in the house next door.

When they encountered each other outside, Martinez-Gaspar would offer the victim

beer.

The day of the incident, the victim was at her house with a friend watching

movies. Her parents were not home. She wanted a beer, so she knocked on the

entrance to Martinez-Gaspar’s residence and asked him for a beer. He invited her in.

They each drank a beer, and then Martinez-Gaspar began touching the inside of the

victim’s thigh. She moved his hand, said “no,” and said that she needed to get back

to her friend. He pushed her onto the bed, forcibly pulled down her shorts and

underwear, and penetrated her with his penis. She ran home, told her friend what had

happened, and called her parents. Her mother called 911.

2. 911 call

Martinez-Gaspar argues that the trial court abused his discretion by prohibiting

him from introducing a statement by the victim’s mother in the recording of her call

to 911 and from asking witnesses about it, because it was a prior inconsistent

statement, not hearsay. See OCGA § 24-8-801 (d) (1) (A). We review that ruling for

2 abuse of discretion and find no such abuse. See Thomas v. State, 293 Ga. 829, 833 (4)

(750 SE2d 297) (2013).

In his opening statement, defense counsel told the jury that when the victim’s

mother called 911 to report the crime, the mother stated that “I think she just jerked

him off or something.” That idea came up again when, on cross-examination, defense

counsel asked the victim, “When you told your mom what happened, is it correct to

say that you told her that you had just jerked him off?” The victim responded, “No.”

The idea came up a third time when defense counsel asked the responding law

enforcement officer whether it was correct that the 911 dispatcher had informed the

officer that “a sexual incident had happened and the alleged victim had just jerked off

the defendant[?]” Before the officer answered, the state objected on the ground that

the question depended on hearsay. The court sustained the objection.

At the beginning of the proceedings the next day, before the jury had entered

the courtroom, the state raised the issue of defense counsel’s references to the mother

telling the 911 operator that she thought that the victim had “just jerked him off or

something.” The state asserted that these references misrepresented what the mother

had said on the 911 call. According to the state, the mother actually said, “I think he

3 just jerked them off or something,” referring to the victim’s clothes. The state asked

to play the recording of the 911 call for the court, and defense counsel agreed.

After the recording was twice played for the court, the state asked the court to

instruct defense counsel not to refer to the victim jerking off the defendant again.

Defense counsel responded that he should be allowed to play the recording for the

jury, and that the jury should decide what the mother said. The court listened to the

recording again and then concluded that the mother had said, “‘He just jerked them

off real quick”; that the victim had been wearing shorts; and that the jerking off

reference was clearly a reference to clothing. The court instructed counsel not to refer

to the victim jerking off the defendant again. Defense counsel moved for a mistrial,

and the trial court denied the motion. The court revisited and reaffirmed the ruling

later in the trial.

Martinez-Gaspar argues that the statement was admissible as a prior

inconsistent statement that contradicted both the mother’s testimony and the victim’s

testimony. See OCGA § 24-8-801 (d) (1) (A) (“An out-of-court statement shall not

be hearsay if the declarant testifies at the trial or hearing, is subject to

cross-examination concerning the statement, and the statement is admissible as a prior

4 inconsistent statement . . . .”). See also OCGA § 24-6-613 (b) (prior inconsistent

statement). He adds that whether the statement was in fact inconsistent was an issue

for the jury.

First we observe that Martinez-Gaspar has not shown that the statement was

inconsistent with the mother’s testimony, because the mother did not testify in court

about the jerking off comment on the 911 call. See Sinkfield v. State, 318 Ga. 531, 545

(6) (a) (899 SE2d 103) (2024) (“extrinsic evidence of a prior inconsistent statement

by a witness shall not be admissible unless the witness is first afforded an opportunity

to explain or deny the prior inconsistent statement and the opposite party is afforded

an opportunity to interrogate the witness on the prior inconsistent statement or the

interests of justice otherwise require[,]” quoting OCGA § 24-6-613 (b)). Although the

court had instructed counsel not to refer to the victim jerking off the defendant again,

Martinez-Gaspar could have proffered what he believed the mother would have

testified or could have asked to question the mother out of the presence of the jury in

order to show that her in-court testimony would be inconsistent with her statement

on the 911 call. See OCGA § 24-1-103 (b). “The burden is on the party alleging error

to show it affirmatively by the record. This (c)ourt cannot determine the propriety of

5 the trial court’s [rejection of Martinez-Gaspar’s argument that the mother’s in-court

testimony would be inconsistent with her statement on the recorded 911 call ] without

a proffer of the excluded evidence or testimony.” Earwood v. State, 350 Ga. App. 26,

32 (2) (827 SE2d 719) (2019) (citations and punctuation omitted). See also Mohr v.

State, 370 Ga. App. 194, 198 (3) (896 SE2d 8) (2023).

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CRUZ v. the STATE.
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Thomas v. State
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State v. Almanza
820 S.E.2d 1 (Supreme Court of Georgia, 2018)
Earwood v. State
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906 S.E.2d 711 (Supreme Court of Georgia, 2024)
Sinkfield v. State
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Guillermo Martinez-Gaspar v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/guillermo-martinez-gaspar-v-state-gactapp-2025.