People v. Paus

CourtSuperior Court of Guam
DecidedJuly 5, 2012
DocketCF0643-11
StatusUnknown

This text of People v. Paus (People v. Paus) is published on Counsel Stack Legal Research, covering Superior Court of Guam primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
People v. Paus, (superctguam 2012).

Opinion

5 IN THE SUPERIOR COURT OF GUAM 6 THE PEOPLE OF GUAM, ) CRIMINAL CASE NO. CF0643-11 7 ) 8 v. ) ) DECISION AND ORDER ON 9 DEFENDANT'S MOTION TO ANTHONY R. PUAS, ) DISMISS 10 ) Defendant. ) II

12 INTRODUCTION I3 This matter came before the Honorable Alberto C. Lamorena, III, on March 14 27, 2012 on Defendant's Motion to Dismiss. Attorney Maria G. Fitzpatrick 15 represented Defendant, Anthony R. Puas. Attorney Brian D. Gallagher 16 represented the People of Guam. Following the hearing the Court took the matter 17 under advisement. Having considered the parties' written and oral arguments, the 18 Court now issues its Decision and Order. 19 FACTUAL HISTORY 20 Defendant was charged by indictment with Second Degree Criminal Sexual 21 Conduct (As a 1st Degree Felony) under 9 G.C.A. §§ 25.20(a)(3) and (b), Second 22 Degree Criminal Sexual Conduct (as a 1st Degree Felony) under 9 G.C.A. §§ 23 25.20(a)(6) and (b), and Felonious Restraint (As a 3rd Degree Felony). The charges 24 stem from an incident in which a female individual (the "victim") was approached 25 by a male suspect in a parking lot late at night. The suspect pulled the victim's 26 hair, pinning her to her car while the suspect grabbed the victim's breast. The 27 victim then kneed the suspect in the groin, thereby allowing her to flee in her 28 Decision and Order Criminal Case No. CF0643-11

vehicle. The victim reported the incident to police and later identified Defendant 2 as her attacker. 3 DISCUSSION 4 Defendant's first contention is that the evidence presented to the grand jury 5 does not support the charge for Felonious Restraint. Defendant then argues that 6 because the felonious restraint charge must be dismissed, there is no predicate 7 felony offense to support the First Charge for First Degree Criminal Sexual

8 Conduct. Finally, Defendant claims that there was insufficient evidence of mental

9 anguish suffered by the victim to support the indictment on the Second Charge for

10 Second Degree Criminal Sexual Conduct. The following discussion first addresses

11 Defendant's arguments related to the Felonious Restraint charge (the Third Charge), and is followed analyses of the First Charge (Second Degree Criminal 12 Sexual Conduct) and the Second Charge (also Second Degree Criminal Sexual I3 Conduct). 14 1. Legal Standard 15

16 Generally, an indictment is valid where the grand jury receives sufficient

17 competent evidence to support a reasonable cause finding that the accused committed an indictable offense. 8 G.C.A. §§ 50.42, 50.54(b). "Reasonable cause 18 amounts to evidence such that 'a man of ordinary caution or prudence would be 19 led to believe and conscientiously entertain a strong suspicion of the guilt of the 20 accused.'" People v. Grajo, 1987 WL109393 at 2 (D. Guam App. Div. 1987). An 21 indictment should not be dismissed prior to trial due to alleged errors in the grand 22 jury proceedings unless it is shown that the defendant is prejudiced by the error. 23 Bank of Nova Scotia v. U.S., 487 U.S. 250, 255 (1988). In order to show prejudice, 24 the challenger must establish that a violation has occurred and that the grand 25 jury's decision to indict was substantially influenced by the violation. Bank of 26 Nova Scotia, 487 U.S. at 255. The person challenging the indictment carries a 27 difficult burden and must demonstrate that the grand jury was deceived by the 28 prosecutor's conduct, thus infringing upon the grand jury's ability to exercise

-2- Decision and Order Criminal Case No. CF0643-11

independent judgment. See U.S. v. AI Mudarris, 695 F.2d 1182, 1185 (9th Cir. 2 1983); U.S. v. Wright, 667 F.2d 793, 796 (9th Cir. 1982). 3 A prosecutor's failure to properly instruct a grand jury may, under certain 4 circumstances, be grounds for dismissal of an indictment. "Erroneous grand jury 5 instructions do not automatically invalidate an otherwise proper grand jury 6 indictment." United States v. Wright, 667 F.2d 793, 796 (9th Cir. 1982) (citing

7 United States v. Linetsky, 533 F.2d 192, 200-201 (5th Cir. 1976». The record must

8 show "that the conduct of the prosecuting attorney was flagrant to the point that

9 the grand jury was 'deceived' in some significant way." United States v. Wright, 667 F.2d 793, 796 (9th Cir. 1982) (citing United States v. Cederguist, 641 F.2d 10 1347, 1352-53 (9th Cir. 1981». The conduct must significantly infringe upon the 11 ability of the grand jury to exercise independent judgment. Id. In regards to the 12 prosecutor's actions regarding preliminary instructions, the prosecutor does not 13 have a duty to instruct the grand jury on the law to the same extent that a judge 14 must instruct a petit jury. People v. Gnass, 101 Cal. App. 4th 1271, 1306, 125 Cal. 15 Rptr. 2d 225, 252 (2002); People v. Calbud, Inc., 49 N.Y.2d 389, 394, 402 N.E.2d 16 1140, 1143 (1980). However, a prosecutor should provide the grand jury statutory 17 definitions of terms whose meaning is not obvious. See People v. Rockwell, 97 18 A.D.2d 853,854,469 N.Y.S.2d 252,254 (1983); People v. Levens, 252 A.D.2d 665, 19 666-67, 677 N.Y.S.2d 390, 392 (1998). With these principles in mind, this Court 20 now turns to the relevant evidence and instructions presented by the prosecution 21 in support of the indictment in this case. 22 II. The Third Charge: Felonious Restraint 23 Defendant first contends that the evidence presented to the grand jury wa 24 insufficient to support the felonious restraint charge. Specifically, Defendant argue 25 that there was no evidence that the accused knowingly exposed the victim t 26 circumstances that would pose a risk of serious bodily injury as required by statute. 27 This Court agrees with the Defendant that there was little evidence presented t 28 support the charge. Perhaps more important to this Court's decision is the fact tha

-3- Decision and Order Criminal Case No. CF0643-11

the prosecution failed to instruct the grand jury on the statutory definition 0 2 serious bodily injury-an essential element of the offense-which this Court find 3 had the likely effect of misleading the grand jury in their decision to indict on the 4 Felonious Restraint charge given the weakness of the evidence presented. 5 The prosecution charged Defendant with Felonious Restraint under title 9, 6 section 22.30(a), which provides:

7 § 22.30. Felonious restraint; Defined & Punished

8 A person commits a felony of the third degree if he knowingly 9 (a) restrains another unlawfully in circumstances 10 exposing him to risk of serious bodily injury 11

12 The definition of the term "serious bodily injury" is adopted from section 16.10(c), 13 which states: 14 Serious Bodily Injury means bodily injury which creates: serious 15 permanent disfigurement; a substantial risk or [sic] death or serious, permanent disfigurement, severe or intense physical pain or protracted 16 loss or impairment of consciousness or of the function of any bodily member or organ. 17

18 9 G.C.A. § 16.10(c). The term "serious bodily injury" is legally distinct from the 19 phrase "bodily injury," which means "physical pain, illness, unconSCIOusness or

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People v. Paus, Counsel Stack Legal Research, https://law.counselstack.com/opinion/people-v-paus-superctguam-2012.