Summary
This First Circuit opinion reviews the conviction of Misael Fabian Medina for attempted sex trafficking of a child and attempted coercion and enticement of a child to engage in prostitution. Medina appealed, arguing that the district court improperly excluded his post-arrest statements under the excited utterance hearsay exception and issued erroneous jury instructions regarding interstate commerce and the distinction between motive and intent. The appellate court found no abuse of discretion in the evidentiary ruling and determined that the jury instructions accurately stated the law without infringing on the jury's fact-finding role or the defendant's Sixth Amendment rights. Consequently, the court affirmed Medina's convictions.
Topics
Practice areas
Questions Presented
- Whether Medina's post‑arrest interview statements qualify as excited utterances under Fed. R. Evid. 803(2) and therefore should have been admitted.
- Whether the district court's jury instruction on the interstate‑commerce element violated Medina's Sixth Amendment rights.
- Whether the district court's jury instruction distinguishing motive from intent violated Medina's due‑process rights.
Holdings
- The district court correctly excluded the post‑arrest interview statements; they were not admissible as excited utterances.
- The instruction did not violate the Sixth Amendment; it was a proper statement of law.
- The instruction was proper and did not violate Medina's rights.
Key quotations
“In determining whether the defendant's conduct was in or affecting interstate or foreign commerce, you may consider whether the defendant used a means or facility of interstate or foreign commerce, such as a telephone or the internet, an entity that serviced interstate or foreign travelers, or the purchase of items that were manufactured outside of Massachusetts.”
“The question of whether someone committed an act knowingly or intentionally should never be confused with the motive for an act. Motive is what prompts a person to act or to fail to act. The concept of motive is different than the concept of knowledge or intent.”
Factual background
Medina, a native Spanish speaker with limited English, responded to an online advertisement that appeared to offer sex with minors. An undercover federal agent posted the ad. Medina arranged a meeting at a Marriott hotel, brought cash and condoms, and was arrested after the agent turned him over to police. At booking he was told he was charged with paying for sex with a minor and responded that he never spoke to any minor. In a post‑arrest interview he reiterated that he believed he was dealing with an adult.
Procedural history
Medina was indicted on two counts of attempted sex trafficking of a child and attempted coercion and enticement of a child. After a hung jury at his first trial, he was convicted at a second trial. He appealed the district court's exclusion of his post‑arrest interview statements under the excited‑utterance exception and challenged two jury instructions—one on interstate commerce and one distinguishing motive from intent.