United States v. Martinez, No. 22-2034 (10th Cir. 2024)
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In the case before the United States Court of Appeals for the Tenth Circuit, the defendant, Jody Rufino Martinez, a member of the Syndicato de Nuevo México (“SNM”), a violent New Mexico-based prison gang, was convicted of murder under the Violent Crimes in Aid of Racketeering (“VICAR”) Act, racketeering conspiracy, and unlawful possession of a firearm. The convictions were related to the 2008 murder of David Romero and the 2018 shooting of Donald Salazar.
On appeal, Mr. Martinez argued that the district court erred in three ways: (1) denying his motion to dismiss under the Speedy Trial Act, (2) admitting unduly prejudicial evidence during trial, and (3) denying his motion for a new trial after evidence emerged that he was involved in threats to kill the presiding district court judge.
The Tenth Circuit affirmed the district court's decisions. The Court held that the district court did not abuse its discretion in denying Mr. Martinez's motion to dismiss under the Speedy Trial Act, which involved a narrow, fact-based argument and did not reveal clear error. The Court also held that the district court did not abuse its discretion in admitting evidence of SNM's violent acts, since the probative value of this evidence exceeded its prejudicial effect. Lastly, the Court held that the judge did not abuse his discretion in declining to grant a new trial, since a reasonable observer would not have expected the judge to know from the testimony heard in the courtroom about the defendant's connection to SNM's threats against the judge.
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