United States of America v. /02-JL Yovannys Guerrero Tejeda and Eric Pineda Mateo

2017 DNH 149P
CourtDistrict Court, D. New Hampshire
DecidedAugust 8, 2017
Docket15-cr-215-01
StatusPublished

This text of 2017 DNH 149P (United States of America v. /02-JL Yovannys Guerrero Tejeda and Eric Pineda Mateo) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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United States of America v. /02-JL Yovannys Guerrero Tejeda and Eric Pineda Mateo, 2017 DNH 149P (D.N.H. 2017).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

United States of America

v. Civil No. 15-cr-215-01/02-JL Opinion No. 2017 DNH 149P Yovannys Guerrero Tejeda and Eric Pineda Mateo

MEMORANDUM ORDER

This case involves whether a variation of marital

privilege, the adverse spousal testimonial privilege, protects

one spouse from testifying against the other when both spouses

jointly participated in criminal activity. Eric Pineda Mateo

(“Pineda”) and his wife, Yovannys Guerrero Tejeda (“Guerrero”),

were arrested and indicted on a number of drug-related offenses.

Ms. Guerrero pleaded guilty to two counts of distribution of

heroin, one count of possession with intent to distribute

fentanyl, and one count of conspiracy to possess with intent to

distribute and to distribute heroin and fentanyl. Mr. Pineda

was charged only with the conspiracy count.

The prosecution, seeking to introduce Guerrero’s immunized

testimony during Pineda’s trial, issued a subpoena to Guerrero

and moved in limine seeking a determination, pursuant to Federal Rule of Evidence 104(a), that her testimony is admissible.1

Guerrero moved to quash the subpoena, invoking the adverse

spousal testimonial privilege.2 The prosecution argues that an

exception to that privilege recognized by, inter alia, the

Seventh Circuit Court of Appeals, vitiates the privilege where

both spouses participated in the charged criminal activity,

rendering her testimony admissible. Concluding that the

substantial weight of authority impresses against recognizing

such an exception, the court grants Guerrero’s motion to quash

the subpoena and denies the prosecution’s motion under

Rule 104(a).

Background3

Guerrero’s involvement in this case began when she answered

a phone call from a confidential informant seeking to purchase

three “fingers” of heroin. On October 6, 2015, she met the

confidential informant in the parking lot of a mall in

1 Rule 104 Motion (doc. no. 57). 2 Mot. to Quash (doc. no. 71). Though, as discussed below, only Guerrero may assert (or waive) this privilege, Pineda also objects to the introduction of her testimony. See Obj. to Rule 104 Motion (doc. no. 67). 3 The court draws this background information from the anticipated testimony described by the prosecution in its pretrial memorandum. See Pretrial Mem. (doc. no. 65) at 1-5.

2 Newington, New Hampshire, where she exchanged a bag of heroin

for $1,000 in cash. The informant contacted Guerrero again on

October 21, asking to purchase an additional five “fingers” of

heroin. Guerrero, this time accompanied by Pineda, met with the

informant to exchange 25 grams of heroin for another $1,000.

After additional conversations over the next several weeks,

the informant and Guerrero arranged a third transaction for

November 16, 2015. Guerrero and Pineda arrived at the pre-

determined location and were arrested by the New Hampshire State

Police, who searched their car and recovered 25 grams of

fentanyl.

Guerrero and Pineda were jointly indicted under 21 U.S.C.

§§ 841(a)(1) and 846 for conspiracy to distribute heroin and

fentanyl and to possess those substances with the intent to

distribute them.4 Guerrero alone was indicted on two counts of

distribution of heroin under 21 U.S.C. § 841(a)(1) and one count

of possession with intent to distribute fentanyl under 21 U.S.C.

§ 841(a)(1). Guerrero pleaded guilty to all four counts.

The prosecution indicated its intention to call Guerrero as

a witness at Pineda’s trial, which was scheduled to begin on

May 8, 2017. To that end, after she asserted her Fifth

4 See Superseding Indictment (doc. no. 48).

3 Amendment right against self-incrimination, the government

sought an order securing her immunity, shielding her against

prosecution based on her testimony.5 After jury selection but

before trial could begin, Guerrero invoked her adverse spousal

testimonial privilege and moved to quash the prosecution’s

subpoena. When the prosecution then stated its intention to

take an interlocutory appeal on an adverse ruling on these

motions, necessitating a delay of the trial, the court dismissed

the panel.6

Analysis

“The court must decide any preliminary question about

whether a . . . privilege exists. In so deciding, the court is

not bound by evidence rules, except those on privilege.” Fed.

R. Evid. 104(a). “[T]he party asserting a privilege bears the

burden of showing that the privilege applies. If the privilege

is established, the burden shifts to the opposing party to show

5 See Mot. to Compel Testimony (doc. no. 64); see also 18 U.S.C. §§ 6001-6003. 6 It was unfortunate, not to mention unnecessary, that the court was forced to release an already-chosen jury, wasting the time of both potential and selected jurors. The prosecution’s intent to appeal an adverse ruling could have been communicated before (and thus eliminating the need for) jury selection. The court ascribes no bad faith or improper motive to the prosecution, but wishes it had proceeded differently.

4 that an exception defeats the privilege.” United States v.

Breton, 740 F.3d 1, 9-10 (1st Cir. 2014). “The common law -- as

interpreted by United States courts in the light of reason and

experience -- governs a claim of privilege” unless the

Constitution, a federal statute, or rules prescribed by the

Supreme Court provide otherwise. Fed. R. Evid. 501.

Guerrero has carried her burden of showing that the adverse

spousal testimonial privilege applies to her testimony.7 The

prosecution has not carried its burden of demonstrating that a

joint-participant exception defeats that privilege.

Accordingly, and for the reasons explained more fully below, the

court grants Guerrero’s motion to quash the subpoena and denies

the prosecution’s motion to admit her testimony.

A. Spousal privileges

“The common law recognizes two related but distinct marital

privileges . . . .” Breton, 740 F.3d at 9. The marital

communications privilege “permits a defendant to refuse to

testify, and allows a defendant to bar his spouse or former

spouse from testifying, as to any confidential communications

made during their marriage.” Id. at 10. This privilege

7 The prosecution does not challenge the fact that Guerrero and Pineda are married, nor does it dispute Guerrero’s right, as Pineda’s spouse, to assert the privilege.

5 protects only those confidential statements made during the

course of a marriage. United States v. Bey, 188 F.3d 1, 4 (1st

Cir. 1999). It is subject to a joint-participant exception,

meaning that “[c]ommunications concerning crimes in which the

spouses are jointly participating . . . do not fall within the

protection of [the] privilege.” United States v. Picciandra,

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2017 DNH 149P, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-of-america-v-02-jl-yovannys-guerrero-tejeda-and-eric-pineda-nhd-2017.