State v. Martinez (Majority)Annotate this Case
In the State of Washington, two brothers, Alejandro S. Martinez and Eduardo S. Martinez, were charged with separate counts of sexually abusing their younger stepbrothers in their shared family home. The State of Washington sought to join the two cases for trial on the grounds that the charges and evidence were virtually identical, and to minimize the number of times the victims would have to testify. Despite objections from both brothers, the trial court granted the State's motion for joinder and both brothers were found guilty as charged. On appeal, the Supreme Court of the State of Washington held that the trial court abused its discretion when it improperly joined the two cases without first meeting at least one of the two bases for joinder under CrR 4.3(b)(3) — whether the offenses were part of a common scheme or plan, or were so closely connected in respect to time, place, and occasion. The court found that the brothers acted independently, were charged with separate criminal acts occurring at separate times, and there was no evidence they acted in concert or as part of a common scheme or plan. The court also found that Alejandro, but not Eduardo, was prejudiced by the joinder. Consequently, the court reversed the Court of Appeals in part and remanded Alejandro's case to the trial court for further proceedings. The court found no violation of Eduardo's constitutional right to due process.