People of Michigan v. Ricardo Garcia-Badillo

CourtMichigan Court of Appeals
DecidedMay 30, 2024
Docket365485
StatusUnpublished

This text of People of Michigan v. Ricardo Garcia-Badillo (People of Michigan v. Ricardo Garcia-Badillo) is published on Counsel Stack Legal Research, covering Michigan Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People of Michigan v. Ricardo Garcia-Badillo, (Mich. Ct. App. 2024).

Opinion

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to revision until final publication in the Michigan Appeals Reports.

STATE OF MICHIGAN

COURT OF APPEALS

PEOPLE OF THE STATE OF MICHIGAN, UNPUBLISHED May 30, 2024 Plaintiff-Appellee,

v No. 365485 Van Buren Circuit Court RICARDO GARCIA-BADILLO, LC No. 2022-023842-FH

Defendant-Appellant.

Before: MALDONADO, P.J., and PATEL and HOOD, JJ.

PER CURIAM.

Defendant appeals by right his bench trial convictions of two counts of second-degree criminal sexual conduct (CSC-II), MCL 750.520c. Defendant was sentenced to serve 2 to 15 years’ imprisonment for both counts of CSC-II, to be served concurrently. We affirm.

I. BACKGROUND

This case stems from allegations made by AA, who was 11 years old at the time of trial, that defendant touched her genitals and breasts. Defendant was in a dating relationship with AA’s mother, and he moved in with AA, AA’s mother, and AA’s brother approximately four months after the relationship began. AA described the incident as follows:

So, I was laying down, sleeping, and it was a school night. And he came and woke me up and he said, “Scooch over,” and I scooched over. And then, I—I thought he was going to like watch TV or something, but then he started laying right next to me, and then he said—he asked me, “Are you ticklish,” and I said, “No,” because I’ve never been ticklish all my life.

And then he started tickling me. He started going under my shirt, and then into my pants, and he touched the side of my vagina. And then, that’s when I scooched over a little bit, far away from him, and then he said, “Are you ticklish in the armpit,” and I said, “No.” And he went through my neck hole, and then he went through my bra, then he touched my left breast and he squeezed it. And then, he let go and he went and started tickling from my armpit.

-1- AA clarified that defendant did not penetrate her vagina.

Then, he said, “I have to go to work,” and then I said, “Okay,” and I said I had to go to the restroom. So, I was on my way, right next to the TV—I was right there, then he decided to pick me up and—he just started picking me up, and then he put me down, and then I went to the restroom, and that’s when I started getting ready for school.

Defendant drove AA and her brother to school, and AA did not tell anybody what happened while she was at school. However, when she got home from school, AA told her mother, and her mother called 911. AA explained that she reported this because she had been taught both in school and by her relatives that being touched “in your private parts” is “not good” even if friends or family do it. AA then disclosed the abuse to a person at the hospital and then to her counselor.

At a later date, defendant was interviewed by a detective, through a Spanish interpreter, about the allegations. The video of the interview was played for the jury, and it was transcribed in the lower court record. Defendant initially stated that he had only tickled AA but he eventually admitted that he put his hand underneath her pants and touched her genital area. When asked about touching AA’s breast, defendant initially maintained that he has only tickled AA’s arm. However, when pressed, he admitted that he also touched her breast. Defendant denied penetrating AA’s vagina and stated that he did not touch either body part for a long period of time.

II. INEFFECTIVE ASSISTANCE OF COUNSEL

Defendant argues that defense counsel rendered ineffective assistance by failing to adequately impeach AA. We disagree.

Claims of ineffective assistance of counsel present mixed questions of fact and law. People v Head, 323 Mich App 526, 539; 917 NW2d 752 (2018). Factual findings are reviewed for clear error and legal conclusions are reviewed de novo. Id.

The Sixth Amendment of the United States Constitution guarantees that criminal defendants receive effective assistance of counsel. Strickland v Washington, 466 US 668, 687- 688; 104 S Ct 2052; 80 L Ed2d 674 (1984). Michigan’s Constitution affords this right the same level of protection as the United States Constitution. People v Pickens, 446 Mich 298, 318-320; 521 NW2d 797 (1994). Accordingly, “[t]o prevail on a claim of ineffective assistance, a defendant must, at a minimum, show that (1) counsel’s performance was below an objective standard of reasonableness and (2) a reasonable probability exists that the outcome of the proceeding would have been different but for trial counsel’s errors.” Head, 323 Mich App at 539 (quotation marks, citation, and alteration omitted). “[A] reasonable probability is a probability sufficient to undermine confidence in the outcome.” People v Randolph, 502 Mich 1, 9; 917 NW2d 249 (2018). This Court presumes counsel was effective, and defendant carries a heavy burden to overcome this presumption. Head, 323 Mich App at 539.

“A convicted defendant making a claim of ineffective assistance must identify the acts or omissions of counsel that are alleged not to have been the result of reasonable professional judgment.” Strickland, 466 US at 690. This Court then evaluates “whether the trial attorney’s acts or omissions were outside the wide range of professionally competent assistance.” People v

-2- Green, 322 Mich App 676, 684; 913 NW2d 385 (2018) (quotation marks and citation omitted). “This Court does not second-guess counsel on matters of trial strategy, nor does it assess counsel’s competence with the benefit of hindsight.” People v Traver, 328 Mich App 418, 422-423; 937 NW2d 398 (2019). However, “a court cannot insulate the review of counsel’s performance by calling it trial strategy.” People v Trakhtenberg, 493 Mich 38, 52; 826 NW2d 136 (2012). The cross-examination of witnesses is a matter of trial strategy. People v Petri, 279 Mich App 407, 413; 760 NW2d 882 (2008). However, “[c]ounsel may provide ineffective assistance if counsel unreasonably fails to develop the defendant’s defenses by adequately impeaching the witnesses against the defendant.” People v Lane, 308 Mich App 38, 68; 862 NW2d 446 (2014).

AA offered testimony at both the trial and preliminary examination regarding videos she viewed on social media, prior to the incident at issue, about stepfathers inappropriately touching stepdaughters. At the preliminary examination, AA testified as follows:

Q. Have you ever talked to your mom about maybe having [defendant] leave?

A. Yes, I have tried because I have this feeling that something was going to go (inaudible). I had this like little something inside me that it was not going to be good and it was turn in wrong [sic] one day.

Q. When you say something was going to turn wrong, are you talking about between [defendant] and your mom?

A. Yeah, I thought they would break up or something and I got—I watched movies how long [sic] step-fathers touch their step-daughters. I was thinking of that but I did ask my ma, (inaudible) and one of my friends.

* * *

Q. But you never really stopped feeling uncomfortable around [defendant]?

A. I would sometimes think that he would like touch me or something because I was always like, you know, would watch these movies and stuff but [sic] step-fathers touch their step-daughters and had that feeling.

Q. When you say step-father touching you, could you be more specific? What did you see about step-fathers touching step-daughters?

A. Like touching their inappropriate body parts.
Q. Where did you see this?
A. In some social media like Netflix or Tik Tok or something like that.

Q.

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
People v. Trakhtenberg
826 N.W.2d 136 (Michigan Supreme Court, 2012)
People v. Petri
760 N.W.2d 882 (Michigan Court of Appeals, 2008)
People v. Carines
597 N.W.2d 130 (Michigan Supreme Court, 1999)
People v. Pickens
521 N.W.2d 797 (Michigan Supreme Court, 1994)
People v. Lane
862 N.W.2d 446 (Michigan Court of Appeals, 2014)
People of Michigan v. Robert Monya Green
913 N.W.2d 385 (Michigan Court of Appeals, 2018)
People of Michigan v. Christopher Duran Head
917 N.W.2d 752 (Michigan Court of Appeals, 2018)
People v. Nix
836 N.W.2d 224 (Michigan Court of Appeals, 2013)
People v. Randolph
917 N.W.2d 249 (Michigan Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
People of Michigan v. Ricardo Garcia-Badillo, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-of-michigan-v-ricardo-garcia-badillo-michctapp-2024.