ARELLANO-CAMPOS v. State
705 S.E.2d 323
Ga. Ct. App.2011Background
- Arellano-Campos was convicted of two counts of rape based on evidence he sexually abused his girlfriend's daughter, I.M.C., starting when she was 11; the rapes relevant to the convictions occurred in May 2004 when I.M.C. was 17; he received a life sentence.
- I.M.C. testified that she was in a long-term, abusive relationship with Arellano-Campos, including threats to her family, beatings, and manipulation to avoid disclosure.
- Evidence included I.M.C.’s testimony, medical/expert testimony, a videotaped interview and statements by Arellano-Campos; the prosecution argued force was established by fear and coercion.
- Arellano-Campos challenged the sufficiency of the evidence and argued ineffective assistance of trial counsel; he claimed the state failed to prove rape beyond a reasonable doubt and that counsel’s representation was deficient.
- The Georgia Court of Appeals rejected both challenges, affirming the convictions and holding that the evidence was sufficient and counsel’s performance, including the handling of a custodial statement, was not ineffective.
- The judgment of conviction and sentence was affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether evidence suffices for rape conviction | Arellano-Campos argues insufficient evidence to prove rape | State contends evidence proves forcible, nonconsensual intercourse beyond reasonable doubt | Evidence sufficient to convict on both counts |
| Ineffective assistance of counsel regarding custodial statement | Arellano-Campos claims counsel erred by stipulating to admissibility of custodial statement | State contends strategy; statements could be impeaching and admissible | No ineffective assistance; stipulation not prejudicial under record |
| Ineffective assistance regarding purported exculpatory evidence | Evidence (photos, notes, reservations, lawsuit) could impeach victim | Counsel not presented because evidence was not properly in record; credibility findings support not admitting | No ineffective assistance; trial court credited counsel’s testimony and found evidence not previously available |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (1979) (sufficiency review requires rational jury could find guilt beyond reasonable doubt)
- Frazier v. State, 298 Ga.App. 487, 680 S.E.2d 553 (2009) (conviction reversed where custodial statement obtained in violation of Miranda; ineffective assistance failed to object)
- Holmes v. State, 284 Ga.330, 667 S.E.2d 71 (2008) (repeated interrogation after invoking right to counsel; Edwards v. Arizona guidance cited)
- Edwards v. Arizona, 451 U.S. 477 (1981) (right to counsel invokes cessation of interrogation unless defendant initiates further communication and waives rights)
- Gassett v. State, 289 Ga.App. 792, 658 S.E.2d 366 (2008) (standard for ineffective assistance, prejudice required)
- Linares v. State, 266 Ga. 812, 471 S.E.2d 208 (1996) (policies on admissibility and impeachment related to custodial statements)