People v. Mendiola

Superior Court of Guam·Decided February 25, 2025·No. CF0723-24·Unknown

Opinion

-gr sf VL L., CLERK GF scum' 11 2025 FEB 2825 25 Vi'i I: 53 FEB25 2 SUPEREGR 3 3 OF GUAM 4

5 5

6 6

7 IN THE THE SUPERIOR SUPERIOR COURT COURT OF OF GUAM GUAM 8

9 THE PEOPLE OF GUAM

10 10 Plaintiff, CRIMINAL CASE NO. CF0723-24 GPD Case GPD Case No.. No.: 24-21062 24-21062 11 11 vs. 12 12 DECISION AND ORDER RE PEOPLE'S EITHEN JAMES FRANKLIN MOTION FOR RELIEF 13 13 AQUININGOC MENDIOLA (aka Either Eithen James Mendiola) 14 14 DOB: 09/11/1999 15 15 FRANK JOSEPH GUMATAOTAO 16 16 REYES JR. 17 17 (aka Frank Joseph Reyes) DOB: 03/14/2000 18 18 Defendants. 19 19

20 20

21 INTRODUCTION INTRODUCTION

22 22 This matter came before the Honorable C. Terlaje on February 24, 2025, for an Honorable John C.

23 23 Evidentiary Hearing on Evidentiary Hearing on the the People's People's Motion Motion for for Relief. Relief Public Public Defender Defender Attorney Attorney William 24 Bischoff Bischoff appeared for Defendant Eithen James Mendiola ("Defendant Defendant Eithen ("Defendant Mendiola"), Attorney 25

Decision and Decision 26 26 Order Re People's Motion for Relief Relief 27 CF0723-24, People PeopleofofGuam Guam v.v. Eithen James James Mendiola and Frank Frank Joseph Joseph Reyes Reyes Page 1 of of9 1 Tend Timblin Terry Timblinappeared appeared for for Defendant Defendant Frank Joseph JosephReyes Reyes ("Defendant ("Defendant Reyes"), and and Special Special 2 2 Assistant Attorney General CurtisVan General Curtis Vande dhveld veldappeared appearedfor the forthe People People ofofGuam Guam ("People"). The ("People"). The 3 Court now issues issuesthe thefollowing following order GRANTING the People's People's Motion Motion to Allow Allow the the Testimony 4 of Former of Former Medical Examiner Dr. Dr. Jeffery Jeffery Nine, Nine, M.D., M.D., via Audio-Video Telecommunication. Audio-Video Telecommunication. 5 BACKGROUND 6 Defendant Mendiola has has been been charged chargedin inthe theIndictment Indictmentwith withMurder Murder(As st (As a 1let Degree 7

8 Felony) and and Aggravated Assault (As Aggravated Assault (As a Second-Degree Felony) with a Special Second-Degree Felony) Allegation of Special Allegation

9 9 Possession and and Use Use of of a Deadly Weapon in the Commission of aa Felony. Defendant Defendant Reyes Reyes has has

10 been charged in the charged in the Indictment Indictmentwith withArson Arson(As (As a Third-Degree Felony), Desecration Desecration (As a 11 11 Misdemeanor), Misdemeanor), Obstructing GovernmentFunction Obstructing Government Function(As (As a Misdemeanor), Misdemeanor), and and Destruction Destruction of 12 12 . . u . . . . Evldence Evidence (As (As aa Mlsdemeanor). Dr. Jeffrey Misdemeanor). Dr. Jeffrey Nine Nlne ("Dr. Nlne") Nine")isisthe theFormer Former Medlcal Medical Examiner Examiner 13 13 of ofGuam, Guam, who performed performed an an autopsy thedeceased autopsy on the deceasedalleged alleged victim victim of ofthe the crimes crimes charged in the 14 14 Indictment Indictment in in this matter, as well well as several other other matters currently pending at the Superior Court 15 15 16 of of Guam. Guam. Dr. Dr. Nine Nine has has since since relocated to Columbus, relocated to Columbus, Ohio, Ohio, and and the the People People have have stated stated that that 16 17 testimony from from Dr. Dr. Nine Nine is is required required to to present present essential proof proof of ofthe the charges charges in in the indictment. 17

18 18 On January 24,2025, January 24, 2025,the thePeople Peoplefiled filedaaMotion Motionfor for Relief, requesting requesting that Dr. Nine that Dr. Nine be

19 allowed allowed to Testify Testify either either via via Audio-Video Audio-Video Telecommunication Telecommunication or by Deposition Deposition in Ohio. Ohio.

20 20 According to the People's Motion, Dr. Nine is unable to travel to Guam the People's Guam to testify testify because because he is 21 a caretaker for his wife wife and and child, child, who whohave haveserious serioushealth health issues. issues. On On February February 7, 7, 2025, Counsel 22 Defendant fo r D e fe n d a n t M e ndiola d i o l a filed fi l e d ann Opposition p p o si t i o n to t o the h e P e o p le's e ' s Motion forr RRelief, o t i o n fo e l i e f, ciciting ting 23 unwillingness to waive waive any any aspects aspects of his Sixth Sixth Amendment confrontation right. 24

25 Decision Decision and and 26 Order Re People's Motion forfor Relief Relief 27 PeopleofofGuam CF0723-24, People Guam v.v. Either EithenJames JamesMendiola Mendiolaand andFrank FrankJoseph Joseph Reyes Reyes Page 2 Page of of 9 1 RULINGS

2 1. I. Preliminary Law Law 3 The Sixth Sixth Amendment Amendment of ofthe the Constitution Constitution guarantees that"[i]n guarantees that "[i]n all criminal prosecutions, 4 the accused shall shall enjoy the right ... to be confronted with with the witnesses against him." witnesses against him." Generally, 5 5 "confrontation" "confrontation"has has been been read as as "face-to-face "face-to-face meeting meeting with withwitnesses witnesses appearing appearing before the trier 6 7 of fact." Coy Coy v. v. Iowa, 487 487 7 U.S. 1012, 1012, 1016 (1988) (citing 1016 (1988) (citing Kentucky v. Sfincer, Stincer, 482 U.S. 730, 7

8 748 (1987)). The Thelast lasttime timethis thisissue issue was was addressed addressed by the U.S. Supreme Supreme Court was in in 1990, 1990, in

99 Maryland v. v. Craig. According to to the the Supreme Supreme Court, Court, "though we reaffirm the importance of importance of

10 10 face-to-face confrontationwith face-to-face confrontation with witnesses witnessesappearing appearingatat trial, trial, we we cannot cannot say say that that such such

11 11 confrontation is an indispensable elementof indispensable element of the the Sixth Amendment's guarantee guaranteeof of the the right to 12 12 confront one's accusers." accusers." 497 U.S. 836, 845(1990). 836, 845 (1990). The Court goes goes on on to say that this this "does "does not, 13 13 of of course, course, mean that itit may mean that may easily easily be dispensed with." Id. dispensed with." Id. If If applied applied literally, literally, the the Sixth Sixth 14 14 Amendment would exclude exclude any statement statement made made by by a declarant declarantnot notpresent presentatattrial. trial. However, However, 15 15

16 doing so so would would nullify nullify virtually virtually every everyhearsay hearsay exception, exception, so so Courts Courts have have long long rejected rejected this this 16 17 blanket view of blanket view of the the Confrontation Clause as Confrontation Clause as"too "too extreme". See See Ohio v. v. Roberts, 448 U.S. 56, 17

18 18 63 (1980). (1980). In Maryland v. v. Craig, the Supreme Court admitted Supreme Court admittedtestimony testimonyvia via a one-way one-way closed

19 19 circuit television procedure. 497 television procedure. 497 U.S. U.S. 836 836 at at 852. 852. In Inmaking makingtheir theirruling, ruling, the the Supreme Supreme Court Court

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