People v. Babauta

Superior Court of Guam·Decided June 25, 2024·No. CF0458-23·Unknown

Opinion

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L/ SUPERIOH SUPERIOR r,~ COURT G l)Er-€;u ·,__,;§ ,,,.J~";% ,. 11 22211 Ju?i 25 FH 52 17 2 CLERK OF COURT OF CDURT 3 3 E?v. I 4 IN THE THE SUPERIOR SUPERIOR COURT COURT OF OF GUAM GUAM 5 5

6 6 OF GUAM THE PEOPLE OF GUAM CRIMINAL CASE no. NO. CF0458-23 CF0458-23

7 vs. _f

8 8 MICHAEL BABAUTA JORDAN MICHAEL BABAUTA (DOB: DECISION DECISION AND ORDER 03/15/1991), Re: Re: Defendant Defendant's Motion to Recuse RecuseAAG AAG Sean 99 BRANDON BRANDON RUFUS RUFUS CHANDLER CHANDLERaka aka Brown (Brando (Brando Rufus Rufus Chandler) Chandler) (DOB: (DOB:02/14/1989), 02/14/1989), 1fO 30 JASON KEITH MANIBUSAN JASON KEITH MANIBUSAN (DOB:(DbB: ,: , 08/20/1977), 08/20/1977), and 11 CYNTHIA ROSE 11 CYNTHIA ROSEQUINATA QUINATA(DOB (DOB:z 10/18/1976), 12 12 Defendants. Defendants. 13 13

14 14 This matter matter came came before the the Honorable Honorable Arthur Arthur R. R. Barcinas Barcinas on on June 2024, on aa 11, 2024, June 11, 15 15 hearing hearing for Defendants' Defendants' Motion to to Recuse Recuse AAG AAGSean SeanBrown. Defendant Jordan Brown.Defendant Michael Jordan Michael 16 16 - Babauta was represented Babauta was representedby byAttorney Attorney Vanessa Williams, Williams, Defendant Defendant Cynthia Quinata Rose Qui Cynthia Rose rata was 17 17 represented by Attorney Minakshi represented by Minakshi Hemlani, Hemlani, and and Defendant Defendant Brandon Brandon Rufus was Chandler was Rufus Chandler 18 18 represented by Attorney William represented by WilliamGavras. Gavras. Defendant DefendantJason Jason Keith Keith Manibusan present, also present, Manibusan was also 19 19 but his counsel, but his counsel, Attorney Attorney David David Lujan, Lujan, was was not. not. Assistant AssistantAttorney General("AAG") AttorneyGeneral Sean ("AAG") Sean 20 Brown Brown was present for for the the People. People. 21 BACKGROUND 22 22 On April April 12, 12, 2024, 2024, Defendant Defendant Chandler filed a Motion Chandler filed Motion to to Recuse Assistant Attorney Recuse Assistant 23 General General Sean Brown ("Motion"), ("Motion"), arguing arguingthat, that, in inprior priorpractice, practice, Attorney Attorney Brown represented Brownrepresented 24 Decision Decision and and Order Ir Criminal Criminal Case CF0458-23,People v.v.Babauta, Case No. CF0458-23, Babita, et et al.

1 1 the the wife wife ofofthe thevictim, victim,and andthat thatthis thisprior priorrepresentation representation taints AAG Brown's taints AAG Brown's continued continued

2 participation in this participation in this case. case. Specifically, Specifically, Defendant Chandler assertsthat Chandler asserts thatthe thevictim's victim's wife wife is an an

3 "obvious "obvious suspect" suspect" in in the the murder of the victim, and thatAAG and that AAG Brown Brown appears to have appears to have overlooked overlooked

4 this matter in his prosecution. prosecution. Chandler Chandler further asserts that, because asserts that, becauseof of said prior relationship,

5 AAG Brown AAG Brownisisprivy privytotomaterial materialfacts factsininthis thiscase, case, potentially potentially including including exculpatory exculpatory evidence,

6 that he has has not not shared sharedwith with Defendants.

7 On the same same day, day, Defendant DefendantBabauta Babautafiled filedaajoinder jointer to to the the Motion, Motion, and and the thePeople People filed filed

8 their Opposition Opposition to the the Motion. Motion. On OnApril April15, 15,2024, 2024,Defendants Defendants Chandler Chandler and and Babauta filed their Babauta filed

9 respective Replies to the People's People's Opposition.

\ 10 10 ,>, On April April 17, 17, 2024> Defendant Manibusa:n 2024; Defendant Manibusanfiled filed aa joinder' jointer to to the the Motion. Motion. On OnApril 329, ApriL'29,

11 11 2024, Defendant Quinata 2024, Defendant Qui rataalso alsofiled filedaajoinder jointer to to the the Motion. Motion.

12 12 On June June ll, 11,2024, 2024,the theCourt Courtheard arguments from heard arguments from the the parties, parties, and and took took the the matter matter

13 13 under advisement. advisement.

14 14 DISCUSSION

15 15 Defendant seeksfor Defendant seeks for AAG AAG Brown Brown to to recuse recuse himself from this matter. matter."[D]isqualification "[D]isqualification

16 16 is aa drastic drastic course course of action action that that should not be taken should not taken simply simply out out of hypersensitivity to ethical ethical

17 17 nuances orthe nuances or theappearance appearanceof ofimpropriety." impropriety."Barrett-Anderson v. Camacho, 2018 Guam Guam 20 ,r 14. 20 1114.

18 18 I. I. The TheGuam GuamSupreme SupremeCourt Courthas hasheld heldthat thatattorney attorneydisqualification disqualification is is warranted warranted

19 19 only when his or her her representation representation violates or significantly significantly risks risks violating the the

20 Guam Rules of of Professional Conduct.

21 The current test test for attorney disqualification disqualification in in Guam Guam is whether an attorney's continued

22 representation orparticipation representation or participationininan anaction action(1) (1)violates violates or or (2) (2) significantly risks violating the the

23 Guam Rules of Guam Rules of Professional Professional Conduct Conduct("GRPC"). ("GRPC"). See See id. ,r 20. "Guam adopted id. 1120. the 2002 adopted the 2002ABA ABA

24 Page 2 of7 of Decision Decision and and Order Criminal Criminal Case Case No. CF0458-23, People v. Babauta, Babita, et et al.

11 Model Model Rules Rules of ofProfessional Professional Conduct Conduct on on September September 29, 2003," and 29, 2003," and "[u]nder "[u]nder the the Model Rules,

2 attorney disqualificationisis warranted attorney disqualification warrantedonly only when when his his or or her her representation representation violates violates or or

3 significantly risks violating significantly risks violating the the Rules of of Professional Professional Conduct." Conduct." Id. 'if 17. Id. 11 17. After the the 2003 2003

4 adoption of the adoption of the GRPC, GRPC, the the "appearance "appearance of ofimpropriety" impropriety" standard set forth standard set forth in in People v. v.

5 Tennessee, Tennessen, 2009 2009 Guam 3, ceased Guam 3, ceased to to be the applicable applicable standard for attorney standard for attorney disqualification in

6 all criminal criminal actions actions filed after after the the GRPC's GRPC'seffective effectivedate. date.Id. 'if 18. Id.11 18. "Although "Although considering considering the

7 appearance of impropriety appearance of impropriety may may be be part part of the inherent of the power of the inherent power the court court as as to regulate regulate the the

8 conduct of attorneys, conduct of attorneys, itit will not not stand stand alone to disqualify disqualify an an attorney attorney in the absence absence of any any

9 indication that that the the attorney's attorney's representation representationrisks risksviolating violatingthe theRules Rules of of Professional Professional Conduct." Conduct."

,} 10 10 Id 'if 17. Id 11 17."Standing "Standingalone, alone,the the'appearance 'appearanceof of impropri.ety' impropnety'lstandard ?·standard is open to widespread wldespread abuse abuse

11 11 and tactical advantage." and exploitation for tactical advantage." Id. Id. Accordingly, the the Court is bound bound to to rely rely exclusively

12 12 on the GRCP in in its its analysis analysis of of the the Motion. The The Court Court also also notes notes that "the disqualification of aa

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