People of Guam v. William Robert Reyes

Summary

The Supreme Court of Guam held that the trial court abused its discretion by denying William Robert Reyes’s motion for a mistrial after permitting cross-examination about prior arrests and an indictment under an inapplicable evidence rule. The court found the error prejudicial, vacated Reyes’s convictions for first- and second-degree criminal sexual conduct, and remanded for a new trial. It nevertheless held that the evidence was sufficient to support the first-degree criminal sexual conduct charge.

Holdings

1. The trial court abused its discretion by allowing the prosecution to question Reyes about prior arrests and an indictment under Guam Rule of Evidence 609, which applies only to prior convictions, and by denying the mistrial motion without analyzing other relevant evidentiary rules or taking corrective measures to address the risk of unfair prejudice.
2. The error was not harmless and required reversal of the convictions because it was more probable than not that the extensive and repeatedly emphasized prior-arrest and indictment evidence materially affected the verdicts.
3. The evidence was sufficient because a rational jury could infer sexual penetration from testimony that Reyes's fingertips passed the labia majora, slightly intruded into the vaginal opening, moved in a circular motion, and caused severe pain.

Questions Presented

1. Whether the Superior Court abused its discretion by denying Reyes's motion for a mistrial after permitting cross-examination about prior arrests and an indictment for alleged crimes that did not result in convictions.
2. Whether the error in allowing the prejudicial cross-examination was harmless.
3. Whether the evidence was sufficient to establish sexual penetration for first-degree criminal sexual conduct.
4. Whether the prosecution improperly used leading questions and argued facts not in evidence during closing argument.

Disposition

reversed_and_remanded