People v. Aguilar

677 P.2d 1198, 35 Cal. 3d 785, 200 Cal. Rptr. 908, 1984 Cal. LEXIS 165
CourtCalifornia Supreme Court
DecidedApril 5, 1984
DocketCrim. 23237
StatusPublished
Cited by59 cases

This text of 677 P.2d 1198 (People v. Aguilar) is published on Counsel Stack Legal Research, covering California Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Aguilar, 677 P.2d 1198, 35 Cal. 3d 785, 200 Cal. Rptr. 908, 1984 Cal. LEXIS 165 (Cal. 1984).

Opinions

Opinion

REYNOSO, J.

The right of a criminal defendant to an interpreter is based on the fundamental notion that no person should be subjected to a Kafkaesque trial which may result in the loss of freedom and liberty. We granted hearing in this case to determine the scope of interpreter assistance which article I, section 14 of the California Constitution requires be afforded a non-English speaking criminal defendant. The trial court properly appointed an interpreter for the accused, Marcello Mata Aguilar, after observing him and speaking with him at his arraignment. That interpreter, however, became unavailable to the defendant during the testimony of two Spanish speaking prosecution witnesses. Mata Aguilar1 was convicted by the jury and he challenges that conviction.

Defendant’s central contention on appeal is that the trial court’s interference with his exclusive access to the interpreter throughout the proceedings deprived him of a constitutional right.

We hold that article I, section 14, requires that when an interpreter is appointed for a non-English speaking accused, the accused has a constitutional right to the assistance of the interpreter throughout the entire proceeding. Accordingly, we find constitutional error in the proceedings below.

[788]*7881. How the Problem Arose

On July 21, 1981, an altercation occurred between two farmworkers employed by Alfred Orosco Ramirez, a Sutter County labor contractor. The two employees, Jose Chaidez and Marcello Mata Aguilar both lived at the nearby labor camp. As the argument between the two Spanish speaking employees became heated, a crowd of fellow employees gathered. The argument escalated into a physical confrontation. Chaidez, the ultimate victim in this case, was the aggressor. The small crowd, which included Chaidez’ son, Jose Aurelio Chaidez, witnessed the events; several persons unsuccessfully attempted to intervene.

Chaidez, who was heavier and taller than Mata Aguilar, delivered several blows to the defendant which caused him to be knocked down. Chaidez then picked up a large stick approximately 30 inches long and threatened and yelled at defendant. Frightened and in pain, defendant got up and retreated to his nearby sleeping quarters where he retrieved his rifle which he kept loaded. Defendant emerged from the building and advanced toward Chaidez. As Chaidez dropped the large stick, defendant fired a single shot.

The police arrived shortly thereafter. They ascertained that Chaidez was dead. Police Detective Wilbur Terry located defendant and took him to the sheriff’s department to be interviewed. During the interview, Detective Terry learned that defendant could neither read or write Spanish, his native language, nor could he read or write English. He could speak only broken English. After being advised of his constitutional rights, defendant agreed to give the detective a statement.2 On August 19, 1981, defendant was charged with murder in violation of Penal Code section 187 and use of a firearm within the meaning of Penal Code section 12022.5.3

[789]*789At defendant’s jury trial, the court appointed an interpreter for him.4 However, his interpreter was “borrowed” by the court to function as a witness interpreter for the benefit of the court and jury when Jose Aurelio Chaidez and Alfred Orosco Ramirez, two prosecution witnesses, were called to testify against him. Chaidez was the first witness for the prosecution. Because he was Spanish speaking, the prosecution suggested that he would need “the interpreter.” Defense counsel, without consulting defendant, acquiesced in the “borrowing” of the interpreter. Chaidez, the only eyewitness other than defendant, testified about the verbal argument that preceded the physical altercation, the actions of his father and defendant prior to the shooting of his father, and defendant’s conduct after the shoot[790]*790ing. Orosco Ramirez was the last witness called by the prosecution. The court again directed that defendant’s interpreter assist the witness in testifying against him. Counsel, again without consulting defendant, acquiesced in this suggestion. Although defense counsel cross-examined Chaidez, no cross-examination of Orosco Ramirez was conducted.

2. The Solution: Constitutional Right to an Interpreter Throughout the Proceedings

a. The Parameters of the Right

Article I, section 14 of the California Constitution was amended in 1974 by vote of the electorate to provide that “[a] person unable to understand English who is charged with a crime has a right to an interpreter throughout the proceedings. ” (Italics added.) The trial court correctly appointed an interpreter for Mata Aguilar, thus complying with the portion of the Constitution which guarantees that an interpreter be provided. However, the trial court failed to follow the last three words of the constitutional provision—“throughout the proceedings”—when it deprived Mata Aguilar of that right by using his interpreter to translate for the prosecution’s witnesses. California’s Constitution does not provide a half measure of protection. Rather, it requires that when an interpreter is appointed for a criminal defendant, that interpreter must be provided to aid the accused during the whole course of the proceedings.

Interpreters play three different but essential roles in criminal proceedings: “(1) They make the questioning of a non-English-speaking witness possible; (2) they facilitate the non-English-speaking defendant’s understanding of the colloquy between the attorneys, the witness, and the judge; and (3) they enable the non-English speaking defendant and his English-speaking attorney to communicate ... an interpreter performing the first service will be called a ‘witness interpreter, ’ one performing the second service, a ‘proceedings interpreter,’ and one performing the third service a ‘defense interpreter.’” (Chang & Araujo, Interpreters for the Defense: Due Process for the Non-English-Speaking Defendant (1975) 63 Cal.L.Rev. 801, 802; hereinafter cited as Chang & Araujo.) While the three roles are interrelated they are distinct.

The defendant’s right to understand the instructions and rulings of the judge, the questions and objections of defense counsel and the prosecution, as well as the testimony of the witnesses is a continuous one. At moments crucial to the defense—when evidentiary rulings and jury instructions are given by the court, when damaging testimony is being introduced—the non-English speaking defendant who is denied the assistance of an interpreter, [791]*791is unable to communicate with the court or with counsel and is unable to understand and participate in the proceedings which hold the key to freedom.5 Thus, the “borrowing” of the interpreter, the accused’s only means of communicating with defense counsel and understanding the proceedings, was a denial of a constitutional right.6

Our conclusion finds support in recent Court of Appeal rulings. People v. Chavez (1981) 124 Cal.App.3d 215 [177 Cal.Rptr. 306], held that a non-English speaking criminal defendant had been denied his constitutional right to receive interpreter assistance throughout the proceedings. The defendant was wholly without an interpreter during portions of the preliminary proceedings dealing with his competence to stand trial. In

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Cite This Page — Counsel Stack

Bluebook (online)
677 P.2d 1198, 35 Cal. 3d 785, 200 Cal. Rptr. 908, 1984 Cal. LEXIS 165, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-aguilar-cal-1984.