Washington v. Juarez (Majority)
Annotate this CaseDefendants were tried together as codefendants, each charged with three counts of first degree assault while armed with a firearm with intent to benefit a criminal street gang. All three defendants appealed, raising a number of issues. The Court of Appeals largely rejected their claims, but found that the trial court had erred in two ways: (1) some of the generalized gang evidence that the trial judge allowed was irrelevant, "had little or no probative value," and was not appropriately limited (however, the Court of Appeals ultimately concluded that the additional generalized gang evidence was unlikely to have materially affected the outcome of the trial, and upheld all three convictions); and (2) the trial court erred when it ruled that the defendants' statements on jail intake forms regarding gang affiliation were voluntary for purposes of the Fifth Amendment. The Court of Appeals explained that "the State's own trial evidence demonstrated that there was a real and ongoing danger of violence and retaliation between rival gangs that presented these defendants with a credible threat of harm if housed with rival gang members in the Sunnyside jail." As a result, the statements were made by the defendants to avoid a very real risk of danger, and thus were not made voluntarily. However, the Court of Appeals found that the latter error was harmless as to two of the defendants (Anthony DeLeon and Robledo) because of other admissible evidence of their gang affiliation, and upheld their gang aggravators. Because of the scant evidence of Ricardo DeLeon's gang involvement, the Court of Appeals reversed his gang aggravator and remanded for a new trial on the aggravator and resentencing. After review, the Supreme Court reversed and remanded for a new trial for all three defendants, finding that they were forced to choose between making incriminating statements and facing physical violence, and that those incriminating statements were then used against the defendants at trial. "Under these circumstances, we do not see how the statements could possibly be considered voluntary and admissible. One should not have to risk physical violence to assert a constitutional right."
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