United States v. Rodriguez, No. 08-50479 (9th Cir. 2014)
Annotate this CaseDefendants Rodriquez, Murillo, and Mujica appealed their convictions for conspiracy to commit murder and first degree murder stemming from the stabbing of a prison inmate, Peter Scopazzi. Because defendants failed to demonstrate that any medical negligence or removal of a breathing tube was so extraordinary that it would be unfair to hold defendants responsible for the resulting death, and because the jury instructions included the concepts of foreseeability and proximate cause, the district court acted within its discretion when it cabined the medical evidence; the district court did not abuse its discretion in admitting evidence pertaining to the connection between the Surenos and the Mexican Mafia as relevant to defendants' motive in attacking Scopazzi; and defendants failed to demonstrate that a new trial was warranted based on the government's failure to disclose immaterial information regarding a government witness's sentence reduction and his cooperation in a DEA investigation. Accordingly, the court affirmed the judgment of the district court.
Court Description: Criminal Law. The panel affirmed three defendants’ convictions for conspiracy to commit murder and first degree murder stemming from the stabbing of a prison inmate, Peter Scopazzi. The panel held that the district court’s exclusion of evidence concerning medical negligence and Scopazzi’s removal of his breathing tube does not warrant reversal of the convictions, where the defendants failed to demonstrate that any medical negligence related to Scopazzi’s multiple stab wounds and his removal of his breathing tube were the sole causes of his death or were so extraordinary and unforeseeable as to absolve the defendants of liability for their vicious assault. The panel held that the district court did not abuse its discretion in admitting evidence of the defendants’ connections to the Mexican Mafia to demonstrate their motive for murdering Scopazzi. The panel also held that expert testimony concerning the connections between the Sureños and the Mexican Mafia within the prison gang hierarchy and photographs of the defendants with Mexican Mafia members did not render their trial unfair because the district court properly minimized any prejudice stemming from the evidence and the trial was replete with admissible evidence regarding the defendants’ gang affiliations. The panel held that the defendants failed to demonstrate under Brady, Mooney, or Napue that a new trial was warranted based on the government’s failure to disclose immaterial information regarding a government witness’ sentence reduction and his cooperation in a DEA investigation.
The court issued a subsequent related opinion or order on September 8, 2014.
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