State v. Sanchez-Diaz

683 N.W.2d 824, 2004 Minn. LEXIS 474, 2004 WL 1688187
CourtSupreme Court of Minnesota
DecidedJuly 29, 2004
DocketA03-1342
StatusPublished
Cited by34 cases

This text of 683 N.W.2d 824 (State v. Sanchez-Diaz) is published on Counsel Stack Legal Research, covering Supreme Court of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Sanchez-Diaz, 683 N.W.2d 824, 2004 Minn. LEXIS 474, 2004 WL 1688187 (Mich. 2004).

Opinions

OPINION

GILBERT, Justice.

In this appeal from a conviction for first-degree murder while committing domestic abuse and second-degree murder of an unborn child, appellant Sergio Sanchez-Diaz asks us to consider four issues. The first is whether the state introduced sufficient evidence to prove the elements of domestic abuse murder; namely, that appellant committed the murder while engaging in domestic abuse and that appellant engaged in a past pattern of domestic abuse. The second is whether the jury instruction defining a past pattern of do[827]*827mestic abuse was erroneous. The third is whether the district court erred in admitting appellant’s statements to police, which contained numerous interpretation errors. The final issue is whether the district court abused its discretion by imposing a consecutive sentence for the second-degree murder of an unborn child conviction.

Because of the nature of appellant’s arguments, it is necessary to review the relevant facts in detail. On the night of December 29, 2001, appellant allegedly stabbed Laura Vazquez Ruelas 13 times, killing her and her unborn child. At the time, appellant was 23 years old and was living with the victim who was 26 years old. They had a 9-month-old son who was born in March of 2001. The victim was also 6 months pregnant with their second child.

The appellant and victim’s intimate relationship began in 1999. They were both recent immigrants from Mexico. They lived together in a mobile home park in Lester Prairie. The victim’s family occupied six mobile homes in the park. In December of 2001, the appellant and victim moved out of their mobile home, which lacked heat, and into lot 15 with one of the victim’s sisters and her family.

On the night of the murder, the victim was at her parent’s trailer with her son playing dominos with family members. Appellant was feeling sick and came to the trailer at around 8:30 p.m. to take their son home so he could go to sleep. Family members testified that appellant appeared angry when he arrived at the trailer and that he slammed the door on his way out. Appellant returned to the trailer about a half hour later, stuck his head in the door, and asked the victim to return home because the child was “crabby.” The victim returned home shortly thereafter.

The victim’s mother was concerned for her daughter’s well being because appellant appeared upset when he arrived at the trailer. She asked two adult male relatives to check on her daughter and appellant. They refused, and she then asked her 13-year-old daughter (the victim’s sister) to go to lot 15. About 5 to 10 minutes elapsed between the time the victim left the trailer and her 13-year-old sister left to check on her. Upon arriving at lot 15, the victim’s sister heard the child crying and ran into the trailer. In the trailer, she observed the victim on the ground unconscious with her child who was physically unharmed next to her. She also saw appellant with a knife in his chest. Appellant told her not to say anything. She ran home, alerted her mother, and someone called 911.

Family members ran to lot 15 and at least five of them entered the trailer before the police arrived. Lester Prairie police officers arrived at the scene at about 9:30 p.m. The officers saw the victim and appellant lying on the floor covered in blood. The victim had a steak knife blade lodged in her upper right shoulder. One of the officers checked the victim’s pulse and did not find a pulse. He then checked appellant’s pulse, eventually felt a faint pulse and called for medical assistance. The officers recovered a wooden knife handle between two couches that matched the blade lodged in the victim. The blood on the knife blade lodged in the victim matched her DNA profile but not appellant’s. The officers found a second bloody knife behind the faucet in the kitchen sink. The blade of that knife contained a mixture of DNA from two people, with the predominant DNA profile matching appellant, and the other profile could not be identified.

The victim was stabbed 13 times in her chest, face, and lower back. The most serious wound pierced her aorta. Her 6-month-old female fetus died as the result of a lack of oxygen circulation. The autop[828]*828sy revealed that the fetus had no apparent congenital or developmental defects or any direct injuries from the stabbing.

Appellant was taken to the emergency room at Waconia Ridgeview Medical Center. He had five stab wounds, three to his upper chest on the left side and two to the middle of his left upper abdomen. One of the stab wounds collapsed a lung. The doctor who treated appellant in the emergency room and a forensic pathologist testified that they could not tell whether any of the wounds were self-inflicted.

The police took a brief statement from appellant in the emergency room at approximately 11:15 p.m. the night of the murder. An interpreter was called to the emergency room. At the time, the interpreter was not a state certified interpreter.1 In that brief statement, appellant told police that he and the victim were arguing, he pushed her on to the bed; she stabbed him and then he took the knife from her and stabbed her.

A BCA agent and a detective took a second more detailed statement from appellant in the hospital two days later on December 31. Investigators utilized the same interpreter. In that statement, appellant said that he and the victim were arguing in the bathroom about the victim’s desire to leave him. During that argument he slapped the victim in her face, took their son to the living room and began putting his jacket on in an attempt to leave. Appellant stated that the victim then stabbed him in the chest; he removed the knife from his chest, stabbed the victim, and then stabbed himself. In that statement, appellant also admitted to grabbing the victim by the neck on a prior occasion and to slapping the victim two or three times in the past. Appellant also stated that the victim was afraid of him. Additionally, when questioned about what the victim’s family members would tell investigators about the way appellant had treated the victim in the past, appellant said that members of the victim’s family knew that he had abused the victim and that “[e]verybody knew how we lived.”

On January 3, 2002, the state charged appellant with second-degree intentional murder and second-degree murder of an unborn child. On February 21, 2002, a grand jury indicted appellant for first-degree murder, second-degree murder, and second-degree murder of an unborn child. The trial was scheduled to begin on January 14, 2003. However, on that day, the two court-appointed interpreters who had reviewed the tapes and transcripts of the interviews indicated to the judge that “significant errors” were made in the translations from English to Spanish and from Spanish to English during the interviews. The court appointed an expert translator to listen to the tapes of the interviews and provide a new transcript. The translator spent a substantial amount of time listening to the tapes of the interviews and she prepared a new transcript detailing the original translation in one column and the corrected translation in the second column.

That transcript identified numerous translation errors from both interviews. Because of the nature of appellant’s arguments, it is necessary to review some of the errors in detail. First, the interpreter made a number of relatively minor interpretation errors throughout both interviews.

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Cite This Page — Counsel Stack

Bluebook (online)
683 N.W.2d 824, 2004 Minn. LEXIS 474, 2004 WL 1688187, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-sanchez-diaz-minn-2004.