People v. Rugante

Superior Court of Guam·Decided March 3, 2020·No. CF0023-14·Unknown

Opinion

I

. r" &8- ILLL SUPEREUR COURT Emma 7.0ZlS%€§;3 -3 PH \: lg gLER5'§OFCOURT J IN THE SUPERIOR COURT OF GUAM v

THE PEOPLE OF GUAM, Superior Court Case No. CF0023-14

Plaintiff; DECISION AND ORDER vs. RE DEFENDANT MINORICHY RUGANTE'S MOTION TO MODIFY MINORICHY NISAR T. RUGANTE, ET BAIL CONDITIONS AL.,

Defendants .

The Court here considers whether to release Defendant Minorichy Rugante on

conditions pending trial. Finding that Rugante poses a serious danger to the community, the

Court DENIES Rugante's Motion to Modify Bail Conditions.

1. PROCEDURAL HISTORY

1. Since January 14, 2014, Defendant Minority Rugante has been committed on $250,000

cash bail.

2. A jury convicted Rugante of two counts of First Degree Criminal Sexual Conduct and

Kidnapping. People u Rugante, 2019 Guam 23 112.

3. However, the Guam Supreme Court reversed the convictions. Rugante, 2019 Guam 23.

The Supreme Court held that the Prosecution failed to disclose exculpatory material in

violation of Brady u Maryland, 373 U.S. 83 (1963) and ordered a new tnlal on remand.

Id. CF0023-14 DECISION AND ORDER RE DEFENDANT MINORICHY RUGANTE'S Page 2 MOTION TO MODIFY BAIL CONDITIONS

4. Now on remand, Rugante asserted his right to a speedy trial, and this Court has scheduled

the trial for April 27, 2020.

5. Pending the trial, Rugante seeks to be released to third party custodians, Rugante's sister

and aunt. The proposed custodians were found to be appropriate, but the Probation

Division recommended the release to be inappropriate due to the lack of a land line and

the severity of charges.

6. Rugante has an extensive criminal record.

a. He served two years of incarceration after pleading guilty to Aggravated Assault

in CF0092-07.

b. He served one year of incarceration after pleading guilty to Aggravated Assault in

CF0233-10.

c. He pled guilty to Disorderly Conduct in CM0383-13, Family Violence in

CM0426-13 and Disorderly Conduct in CM0665-13.

II. LAW AND DISCUSSION

Guam law requires a com to order a person "charged to be released On recognizance,

unless the judge determines, in his discretion, on the basis of available information, that such a

release will not reasonably assure the appearance of the person as required or will endanger the

safety of any other person or the community." 8 GCA § 40.15(b). Moreover, the judge shall

consider:

(1) the nature of the offense charged, the apparent possibility of conviction and the likely sentence;

(2) the history and characteristics of the person charged, including:

(i) length of his/her residence on Guam,

(ii) his/her employment status and history, and financial

om! E L CF0023-14 DECISION AND ORDER RE DEFENDANT MINORICHY RUGANTE'S Page 3 MOTION TO MODIFY BAIL CONDITIONS

condition;

(iii) his/her family ties and reladonshipsg

(iv) his/her reputation, character and mental and physical condition,

(v) his/her prior criminal record, if any, including any record of prior release on recognizance or on bail,

(vi) his/her history relating to drug or alcohol abuse,

(vii) the identity of the reasonable members of the community who will vouch for his/her reliability;

(viii) whether, at the time of the current offense or arrest, he/she was on probation, on parole or on other release pending trial, sentencing, appeal or completion of sentence of an offense under Federal, state or local law, and

(ix) his/her history of compliance with other Court orders,

(3) the nature and seriousness of the danger the person would pose to the community or to any individual member thereof if released; and

(4) any other factors which bear on the risk of willful failure to appear or the danger the person would pose to the community or to any individual member thereof if released.

8 GCA § 40.15(c). The law further instructs the Court, should it not release a defendant on his

own recognizance, to impose the least onerous condition such as placing the person in the

custody of a third party custodian, restricting the defendant's movements, requiring the execution

of a bond, imposing a curfew, or any other condition reasonably necessary to assure the

appearance of the defendant as required and the safety of any other person and the community. 8

GCA § 40.20.

The Court will now consider the relevant factors.

ORH5 ,X\ CF0023-14 DECISION AND ORDER RE DEFENDANT MINORICHY RUGANTE'S Page 4 MOTION TO MODIFY BAIL CONDITIONS

1. Nature of the Offense Charged, Apparent Possibility of Conviction

Rugante faces counts of First Degree Criminal Sexual Conduct and Kidnapping. The

allegations that Rugante and others intentionally and forcibly sexually penetrated the victim in

this case raise community safety concerns of the highest level.

During this new trial, however, the People do not expect die victim to testify. W hile this

may have some impact on the possibility of conviction, the People intend to call other witnesses

with knowledge of Rugante's involvement in the alleged criminal acts. The Court therefore finds

that despite the possible absence of the victim at trial, there is still a possibility of conviction.

2. History and Characteristics of Person Charged

Rugante has a long criminal history. Prior to being charged in this case, he pled guilty to

assault, family violence, and disorderly conduct charges in five separate cases and agreed to

serve three years of incarceration. Three of those cases occurred within a year prior to the

charges in this case. Based on this pattern, the Court is convinced that but for his confinement

for the past six years, Rugante would likely have continued to amass criminal charge after

criminal charge.

3. Nature and Seriousness of the Danger the Person Would Pose to the Community or to any Individual Member thereof if Released

As just described, Rugante faces the highest degree of criminal sexual conduct charges.

If those charges are proven, Rugante poses a grave danger to the community, even if the victim is

no longer present on Guam.

4. Other Factors

At the motion hearing, the Court inquired as to whether the length of detention impacted

the Court's release analysis. Rugante filed additional briefing which argued that federal law

recognizes that excessive delay in bringing a matter to trial is presumptively prejudicial. Suppl. CF0023-14 DECISION AND ORDER RE DEFENDANT MINORICHY RUGANTE'S Page 5 MOTION TO MODIFY BAIL CONDITIONS

Briefing (Feb. 24, 2019). Rugante also attributes this delay to the Prosecution's insistence on not

disclosing the Brady material. Id.

Guam law does not include the length of detention as a factor for the Court's

consideration, although federal law does take it into consideration in release motions. "Although

the length of pretrial detention is one factor courts are to consider, it alone is not dispositive and

carries no fixed weight 'm a due process analysis." United States v Stanford, 722 F. Supp. ad

803, 807 (S.D. Tex.), a/Td, 394 F. App'x 72 (5th Cir. 2010). While six years of pretrial detention

may be excessive, the Court finds this factor is outweighed by the seriousness of the charges,

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
United States v. Robert Stanford
394 F. App'x 72 (Fifth Circuit, 2010)