Arellano-Campos v. State
307 Ga. App. 561
| 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., since she was eleven; the rapes occurred in May 2004 when I. M. C. was 17.
- He was sentenced to life in prison.
- On appeal from the denial of his motion for a new trial, Arellano-Campos challenges sufficiency of the evidence and the effectiveness of trial counsel.
- The victim testified to threats and coercion, ongoing abuse beginning at age 11, and multiple rapes, supported by physical examination and police testimony.
- The defense presented alibi-like and corroborating testimony; the state presented expert medical testimony and admissions by Arellano-Campos.
- The appellate court affirmatively held the record supported the verdict and denied the ineffective-assistance claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict for rape | Arellano-Campos argues contradictions negate proof. | Arellano-Campos contends no force/consent proven beyond reasonable doubt. | Evidence sufficed; rational fact-finder could find elements beyond reasonable doubt. |
| Ineffective assistance of counsel (custodial statement) | Counsel failed to suppress Miranda-violating custodial statement. | Stipulation to admissibility was deficient representation. | No reversible error; failure to suppress would not have changed outcome; trial strategy issues supported by record. |
| Ineffective assistance—exculpatory evidence not presented | Evidence (photos, notes, travel records) could impeach victim’s testimony. | Counsel lacked access to evidence; not presented at trial. | Trial court credibility findings binding; no error in denying ineffectiveness on this ground. |
Key Cases Cited
- Jackson v. Virginia, 443 U.S. 307 (U.S. 1979) (standard for reviewing sufficiency of evidence)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) ( Miranda warnings and admissibility principles)
- Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel and invocation rules)
- Frazier v. State, 298 Ga. App. 487 (Ga. App. 2009) (trial counsel deficient for not challenging custodial statement under Miranda)
- Gossett v. State, 289 Ga. App. 792 (Ga. App. 2008) (standards for ineffective assistance and admissibility considerations)
- Miller v. State, 285 Ga. 285 (Ga. 2009) (reaffirming sufficiency review and related doctrines)