People v. Potts

CourtSuperior Court of Guam
DecidedFebruary 20, 2019
DocketCF0241-16
StatusUnknown

This text of People v. Potts (People v. Potts) 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. Potts, (superctguam 2019).

Opinion

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FILED . l SUPERIOR COURT OF GUAN 2 ZOISFEB 20 PH l=27 3 CLERKOFCOURT 4

6 IN THE SUPERIOR COURT OF GUAM 7

8 THE PEOPLE OF GUAM, CRIMINAL CASE no. CF0241-16 9

10 vs. DECISION AND ORDER

12 DEVIN TAYLOR TAITANO POTTS I 13 Defendant. 14

15 INTRODUCTION

16 This matter came before the Honorable Vernon P. Perez on November 28, 2018, for

17 hearing on Defendant Devin Taylor Taitano Potts' ("Defendant") Motion to Sever Counts.

18 Defendant was not present, but was represented by counsel, Attorney Delia W olff. Assistant

19 Attorney General James C. Collins was present on behalf of the People of Guam ("the

20 Government"). Having reviewed the pleadings, the arguments presented, and the record, the

21 Court now issues the following Decision and Order.

22 BACKGROUND

23 On April 14, 2018, Defendant was indicted with two counts of Possession of a Schedule

24 II Controlled Substance (As a Third Degree Felony).l (Indictment, Apr. 14, 2018). Count One

25 alleges that Defendant possessed a Schedule H Controlled Substance on or about November 24,

26 I The Indictment also charges co-defendant Marcus Damian with one count of Possession of a Schedule II 27 Controlled Substance (As a Third Degree Felony). Co-defendant Damian entered into a global plea agreement with the Government on December 13, 2017, and is currently serving a sixty-two (62) month sentence at the Department 28 of Corrections. See Plea Agreement, Dec. 29, 2017, Judgment, Sep. 20, 2018.

People v. Potts Case No. CF024l-I6 Decision and Order

Page 1 of 4 I 2015, while Count Two alleges that Defendant possessed a Schedule II Controlled Substance on

2 or about February 1 2 , 2 0 1 6 . Id. B ot h c ount s st e m from t he d i sc ove ry of suspe c t e d

3 methamphetarnines in Defendant's possession during a traffic stop.

4 On October 8, 2016, Defendant filed the instant Motion. On October 22, 2018, the

5 Government tiled its Opposition. No Reply was filed. On November 28, 2018, the Court heard

6 oral arguments on the Motion and subsequently placed the matter under advisement.

7 DISCUSSION

8 Defendant moves the Court to sever the two counts of Possession of a Schedule II

9 Controlled Substance for trial pursuant to 8 G.C.A. § 65.35. See generally, Mot., Oct. 8, 2018.

10 Under Guam law, two or more offenses may be charged in the same indictment "if the

offenses charged are of the same or similar character or based on the same act or transaction or

12 on two or more acts or transactions connected together or constituting parts of a common

13 scheme or plan." 8 G.C.A. § 55.35.2 However, "if it appears that a d efend ant or the

14 government is prejudiced by a jointer of offenses .. . in an indictment or information or by such

15 jointer for trial together, the court may order an election or separate trials of counts. as 8 16 G.C.A. § 65.35.

17 W hen determining whether offenses are properly joined, courts traditionally consider

18 "whether the charges are laid under the same statute, whether they involve similar victims,

19 locations, or modes of operation, and the time frame in which the charged conduct occurred."

20 United States v. Taylor, 54 F.3d 967, 973 (let Cir. I995) (citations omitted). Furthermore, "the

21 validity of the jointer is determined solely by the allegations in the indictment." United States

22 v. Jawara, 474 F.3d 565, 572 (9th Cir. 2007) (citing United States v. Terry, 911 F.2d 272 (9th

24 1 Section 55.35 is substantially the same as Rule 8 of the Federal Rules of Criminal Procedure. See 8 G.C.A. § 25 55.35, Note. Rule 8(a) provides:

26 (a) Joiner of Offenses. The indictment or information may charge a defendant in separate counts with 2 or more offenses if the offenses charged - whether felonies or misdemeanors or both - are 27 of the same or similar character, or are based on the same act or transaction, or are connected with or constitute parts of a common scheme or plan. 28 Fed. R. Crum. p. 8.

People v. Ports Case No. CF024l- 16 Decision and Order

Page 2 of 4 I Cir. 1990)). "At least one of Rule 8(a)'s three conditions must be satisfied for proper jointer, 2 and 'those conditions, although phrased iN general terms, are not infinitely elastic."' ld. at 573

3 (citation omitted). "[T]he primary purpose of Rule 8(a) jointer is to ensure that a given

4 transaction need only be proved once. ... Where there is substantial overlap in evidence

5 between two offenses, jointer eliminates the need to prove substantially the same evidence

6 twice over, thus realizing precisely the kind of economy envisaged by Rule 8(a)." Howerton v.

7 United States, 964 A.2d 1282, 1292 (D.C. 2009). (citations, internal quotation marks, and

8 alterations omitted). See also Terry, 911 F.2d at 276 ("When ... joined offenses are not

g connected and are not provable by the same evidence, jointer is improper.").

10 Here, Defendant argues that it will be extremely prejudicial for the counts to be tried

11 together in front of azury, that the charged acts are "separate and distinct from each other," and

12 there is no evidentiary overlap. (Mot. at 3). The Government, in opposition, argues that both

13 counts involve simple drug possession resulting in a "joint arrest" in March 2016, there is not a

14 significant period of time lapsing between both incidents, and that testimony will overlap for

15 both incidents concerning Defendant's "discussions with law enforcement in regards to

16 potential co-operation and his later simultaneous arrest." (Opp'n at 3).

17 Accordingly, the issues before the Court are whether jointer is appropriate under the

18 "same or similar character" prong and whether Defendant is prejudiced by such jointer. The

19 "same or similar character" prong "is the most amorphous and controversial of the three 20 grounds forjoinder." Id. at 575.

21 Numerous courts and commentators have questioned the logic and fairness of such a rule. See e.g., Randazzo, 80 F.3d at 627 ("It is obvious why Congress 22 provided for jointer of counts that grow out of related transactions the reasons 23 for allowing jointer of offenses having 'the same or similar character' is less clear."), Helper, 590 F.2d at 430 ("When all that can be said of two separate 24 offenses is that they are of the 'same or similar character,' the customary 25 justifications for jointer (efficiency and economy) largely disappear.... At the 26 same time, the risk to the defendant in such circumstances is considerable."), Note, Joint and Single Trials under Rule 8 and 14 of the Federal Rules of 27 Criminal Procedure, 74 Yale L.J. 553, 560 (1965) (recommending "abolition of 28 jointer of similar offenses under Rule 8" given its "lack of utility" and risk of

People v. Potts Case No. CF024l-16 Decision and Order

Page 3 of 4 prejudice to the defendant); lA Charles Alan Wright, Federal Practice And I Procedures 143 (ad ed. 1999) ("Joiner on this ground poses obvious dangers of 2 prejudice to the defendant....

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Related

United States v. Taylor
54 F.3d 967 (First Circuit, 1995)
United States v. Edward Terry
911 F.2d 272 (Ninth Circuit, 1990)
Howerton v. United States
964 A.2d 1282 (District of Columbia Court of Appeals, 2009)

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