Joseph Rodriguez-Berdecia v. State of Arkansas

2024 Ark. App. 614
CourtCourt of Appeals of Arkansas
DecidedDecember 11, 2024
StatusPublished
Cited by1 cases

This text of 2024 Ark. App. 614 (Joseph Rodriguez-Berdecia v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph Rodriguez-Berdecia v. State of Arkansas, 2024 Ark. App. 614 (Ark. Ct. App. 2024).

Opinion

Cite as 2024 Ark. App. 614 ARKANSAS COURT OF APPEALS DIVISION III No. CR-24-26

Opinion Delivered December 11, 2024

APPEAL FROM THE WASHINGTON JOSEPH RODRIGUEZ-BERDECIA COUNTY CIRCUIT COURT APPELLANT [NO. 72CR-21-726]

V. HONORABLE MARK LINDSAY, JUDGE STATE OF ARKANSAS APPELLEE AFFIRMED

CINDY GRACE THYER, Judge

Joseph Rodriguez-Berdecia was convicted by a Washington County jury of three

counts of rape; one count of first-degree sexual assault; one count of second-degree sexual

assault; and one count of first-degree domestic battering and was sentenced to a combined

total of eighty years1 in the Arkansas Division of Correction. On appeal, he argues that (1)

there was insufficient evidence to support his convictions and (2) that the State

impermissibly attempted to shift the burden of proof during closing arguments. We affirm.

1 Appellant received forty years on each of the three rape counts, with two of the sentences to run consecutively. The forty-year sentence on the third rape count and the sentences on the other three convictions (twenty years, fifteen years, and one year, respectively) were ordered to run concurrently to the consecutive sentences on the first two rape counts. In February 2021, the minor victim (MV) reported to her mother that her mother’s

former boyfriend (appellant Rodriguez-Berdecia) had sexually assaulted her several years

prior. Following this revelation, MV’s mother took her to the Springdale police station to

report the assault.

After an investigation into the matter, appellant was ultimately charged with two

counts of rape of a minor under the age of fourteen; one count of rape of a minor by a

guardian; one count of first-degree sexual assault involving a minor and a person in a position

of trust or authority; one count of second-degree sexual assault involving a minor under the

age of fourteen; and one count of third-degree domestic battering for causing physical injury

to a household member with a knife.

A three-day jury trial was held in August 2023. The State called six witnesses:

Springdale Police Sergeant Robert Hammontree; Dale Chiddester, a civilian investigator

with the Arkansas State Crimes Against Children Division (CACD); Barbara Ervin, a sexual

assault nurse examiner (SANE); Karen Blackstone, a forensic interviewer at the Children’s

Safety Center (CSC); MV; and MV’s mother, Nancy Aguirre.

Sergeant Hammontree testified that he was assigned to investigate MV’s sexual-assault

allegations against appellant, which reportedly occurred when MV was thirteen years old. He

stated that, although there had been an approximately four-year delay in disclosing the

assault, delayed disclosure was not unusual in those types of cases.

2 As part of his investigation, Hammontree arranged for forensic interviews of MV and

her siblings at the CSC.2 MV’s interview at the CSC, which he observed, occurred on

February 24, 2021. He also discussed the allegations with appellant, who denied them. After

questioning appellant, Sergeant Hammontree arrested him.

On cross-examination, Sergeant Hammontree admitted he had not obtained a search

warrant for the residence where the crimes allegedly occurred,3 nor did he attempt to collect

any additional physical evidence due to the delay in reporting. He also testified that, although

he was aware that MV had been to Vantage Point for mental-health issues, he had not made

any attempts to obtain her medical records. He further denied knowing that MV had accused

someone else.

Dale Chiddester explained forensic-interviewing techniques and the various reasons

why child victims might delay reporting abuse. He then testified that he had conducted MV’s

February 24 interview regarding her allegations against appellant. He stated that he had not

seen any of the signs indicative of lying during that interview. After the interview, he

requested that MV undergo a forensic medical examination because she had disclosed

penetration and that one of the incidents reportedly resulted in a scar. He stated that he also

2 He did not set up a medical exam because of the delayed disclosure. The siblings’ interviews did not produce any additional evidence. 3 At the time of the investigation, the parties no longer lived at that residence.

3 observed the interviews of MV’s siblings, but none of them reported any sexual abuse. 4 At

the conclusion of his investigation, he issued a true finding as to MV’s allegations.

Barbara Ervin testified that she performed a forensic medical examination on MV on

March 4, 2021. The exam was normal. Ervin testified, however, that it is very common to

have normal exams after an alleged assault, and in fact, over 90 percent of the exams in these

situations—even exams of pregnant teenagers—are normal. She further testified that, given

the delayed disclosure and the four years that had elapsed since MV’s last physical contact

with appellant, any injury sustained would have healed by the time the exam was performed.

She did report finding a one-inch scar on MV’s lower left buttock and inner thigh, which

MV claimed to have received during one of the assaults. A photograph of the scar was

admitted and shown to the jury.

Karen Blackstone described the multiple reasons a child might delay disclosure of

abuse. She admitted on cross-examination, however, that she had no way of telling whether

any particular child was telling the truth about alleged abuse.

MV was the next to testify. She testified that appellant had raped her on multiple

occasions. She testified that when these incidents allegedly occurred, she was twelve or

thirteen years old, and appellant was living with her, her sisters, and her mother in a house

in Springdale.5

4 One of the children did disclose domestic violence between appellant and Nancy but nothing sexual between the appellant and the other children. 5 She testified she was approximately fourteen and entering the eighth grade when her mother left appellant, and they moved out of the home.

4 MV claimed that the first incident occurred when she was cleaning her bedroom. She

and appellant were alone in the house at the time. Appellant entered the room; accused her

of watching pornography on her phone; grabbed her breast; and told her that he knew she

liked it. When she responded that she did not like it, he told her not to tell her mother.

According to her testimony, a few nights later, appellant entered her room while she

was in bed. He crawled on top of her, grabbed her arms, and pinned her down with his

knees. He then pulled down her pants and underwear and penetrated her vagina with his

penis. She told him to stop and that it hurt, and she tried to push him off. He refused and

ordered her to be quiet. He did not wear a condom during the assault, and MV believed he

pulled out before he ejaculated. She said he left marks on her hands and that she wore

hoodies at his suggestion to hide the bruising. He warned her not to tell anyone or he would

rape her sisters, too, so she remained silent. He also told her that her mother would not

believe her.

On another occasion that summer, appellant entered the bathroom while MV was

showering and touched her naked breast. Although she was crying, he told her that he knew

she liked it.

The next assault occurred while MV was in a bedroom she shared with one of her

sisters. She was alone in the room at the time.

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2024 Ark. App. 614, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-rodriguez-berdecia-v-state-of-arkansas-arkctapp-2024.