State v. Pena Fuentes

CourtWashington Supreme Court
DecidedFebruary 6, 2014
Docket88422-6
StatusPublished

This text of State v. Pena Fuentes (State v. Pena Fuentes) is published on Counsel Stack Legal Research, covering Washington Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Pena Fuentes, (Wash. 2014).

Opinion

Fl LE

IN THE SUPREME COURT OF THE STATE OF WASHINGTON

STATE OF WASHINGTON, ) ) Respondent, ) No. 88422-6 ) v. ) EnBanc ) JORGE NAHUN PENA FUENTES, ) ) Filed _ _;_F-=EB"'-,-""-0_,_8_,_20 .14..___ .. . Petitioner. ) ___________________________)

OWENS, J. -- The Sixth Amendment guarantees a criminal defendant the

right to assistance of counsel, which includes the right to confer privately with that

counsel. State intrusion into those private conversations is a blatant violation of a

foundational right. We strongly condemn "the odious practice of eavesdropping on

privileged communication between attorney and client." State v. Cory, 62 Wn.2d 371,

378, 382 P.2d 1019 (1963). We presume that such eavesdropping results in prejudice

to the defendant and have vacated criminal convictions when there was no way to

isolate the prejudice to the defendant from such "shocking and unpardonable

conduct." ld. State v. Pena Fuentes No. 88422-6

In this case, we are asked whether a conviction must be vacated even if it were

shown that the eavesdropping did not result in any prejudice to the defendant-in

other words, whether the presumption of prejudice from such eavesdropping is

rebuttable. That question is crucial in this case because here, the police detective

eavesdropped on attorney-client conversations after the trial was complete and the

jury had found the defendant guilty. Thus, while the conduct was unconscionable,

there was no way for the eavesdropping to have any effect on the trial itself. Further,

the prosecutor submitted a declaration stating that the detective on the case never

communicated any information about the attorney-client conversations to the

prosecution.

In light of these circumstances, we hold that eavesdropping is presumed to

cause prejudice to the defendant unless the State can prove beyond a reasonable doubt

that the eavesdropping did not result in any such prejudice. In this case, the record

does not provide enough information to make this determination, and we remand for

additional discovery.

FACTS

While the most significant issue in this case involves the detective

eavesdropping on conversations between Jorge Nahun Pefia Fuentes and his attorney,

there are also legal challenges to four other rulings: (1) the trial judge's decision

regarding discovery related to the eavesdropping, (2) the trial judge's evidentiary

2 State v. Pena Fuentes No. 88422-6

ruling related to a letter by Pefia Fuentes's daughter (who is also the victim's half

sister), (3) the trial judge's ruling that Pefia Fuentes's convictions for both rape of a

child and child molestation violated his double jeopardy rights, and (4) the Court of

Appeals' denial ofPefia Fuentes's motion to supplement the record. Below is a

summary of the basic facts in this case, as well as the facts related to each of the

various legal issues.

J.B. Reports Abuse

In November 2008, ninth grader J.B. told her school counselor that her

stepfather, Pefia Fuentes, had touched her inappropriately when she was younger. The

counselor immediately contacted Child Protective Services and J.B.'s parents. The

police investigated, and Pefia Fuentes was eventually charged with first degree rape of

a child, three counts of first degree child molestation, and three counts of second

degree child molestation.

Overview of the Trial

Pefia Fuentes was put on trial in October 2010. Because of the ongoing nature

of the abuse and the limitations of J.B.'s memories from childhood, the prosecution

did not know the specific dates of particular incidents of abuse. However, J.B. could

recall the location of abuse, and because the family had moved somewhat frequently,

the different incidents of abuse could be connected with specific time periods based

on where the family was living when the abuse occurred. Therefore, the prosecution

3 State v. Pefia Fuentes No. 88422-6

based its charges on conduct occurring during a certain time period, which it

determined based on where the family was living at the time:

• Count II was based on abuse alleged to have occurred while the family was living at an apartment in Bellevue, between November 26, 2000 and June 1, 2003.

• Counts I, III, and IV were based on abuse alleged to have occurred while the family was living at a condo between January 1, 2003 and November 25, 2005.

• Counts V, VI, and VII were based on abuse alleged to have occurred after Pefia Fuentes and J.B. 'smother had divorced, while J.B. was living with her mother in Sammamish and Pefia Fuentes was living in Redmond between November 26, 2005 and November 25, 2007.

At trial, J.B. testified about many incidents of inappropriate touching,

beginning when she was in first grade. Her memories of the early abuse at the

Bellevue apartment (related to count II) were "[n]ot very good," 2 Verbatim Report of

Proceedings (VRP) at 322, and the jury ultimately found Pefia Fuentes not guilty on

count II.

J.B.'s memories of later abuse at the condo (related to counts I, III, and IV)

were much clearer. She testified in detail about repeated incidents ofPefia Fuentes

abusing her at the condo. !d. at 329-30. J.B. also testified about two specific and

particularly severe incidents involving penetration that occurred while they were

living at the condo. The jury ultimately found Pefia Fuentes guilty on counts I, III,

and IV.

4 State v. Pena Fuentes No. 88422-6

J.B. indicated that the abuse was less frequent after Pefia Fuentes and her

mother divorced. During this time, lB. testified that the abuse occurred at Pefia

Fuentes's home in Redmond (related to counts V, VI, and VII). The jury was unable

to reach unanimity on the remaining charges.

No witnesses directly corroborated or refuted J.B.'s testimony. Some of the

State's witnesses, including lB.'s grandmother, testified that lB. sometimes

expressed disco_mfort about having to go to Pefia Fuentes's house, and two of lB.'s

friends testified that she had alluded to the abuse in previous years.

Pefia Fuentes himself did not testify at trial, but the original police interview of

Pefia Fuentes was submitted as evidence. During that interview, he denied most of the

abuse but acknowledged a few incidents that occurred while he was roughhousing

with J.B.

L.P. 's Testimony at Trial

Most of the issues now in front of us arise out of a series of events that began

with a letter written by J.B. 'shalf sister, L.P. L.P. is about four and a half years

younger than lB. and has the same mother, but is the biological daughter ofPefia

Fuentes. At trial, the defense introduced a letter to the prosecutor that L.P. had

written when she was 11 years old. In the letter, L.P. indicated that she believed lB.

was lying at the behest of their mother based on a conversation she had overheard

between them. In her deposition, L.P. indicated that she could not recall whose idea

5 State v. Pena Fuentes No. 88422-6

the letter was, and that she could no longer remember what she had overheard her

mother say to J.B.

The trial judge allowed the jury to consider the letter in order to assess L.P.' s

credibility-i.e., for impeachment purposes only-but not for the truth of the matter

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Weatherford v. Bursey
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State v. Pena Fuentes, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-pena-fuentes-wash-2014.