El Pueblo De Puerto Rico v. Gonzalez Cabrera, Ana Luisa, KLCE202400038

Ana Luisa González Cabrera was charged, along with Juan Enrique Catalá Suárez, with conspiracy, offering a bribe, and witness tampering related to alleged conduct in November 2022.
Following arrest and formal charges, extensive motions for discovery were filed under Rule 95 of Puerto Rico’s Criminal Procedure Rules.
The defense specifically sought access to text messages and forensic data from the cell phone of a key prosecution witness, arguing the State’s extraction was incomplete.
The trial court ordered partial discovery: permitted some requests, denied others, and, eventually, allowed defense-performed extraction of the prosecution witness’s phone.
The People (government) and González Cabrera each sought certiorari, contesting the trial court’s interlocutory discovery rulings.
The appeals court consolidated the petitions to address both the scope of required discovery—especially regarding digital evidence from third-party phones—and the defendant's requests for specific documents and identification of intended prosecution evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Access to witness cell phone for defense forensic extraction	Needed to ensure completeness & integrity of digital evidence	Allowing defense extraction is unwarranted; the State’s extraction suffices and phone contents are constitutionally protected	Lower court erred in permitting extraction without first defining scope and safeguards; remanded for hearing to address need, scope, and privacy protections
Production of witness’s sworn statement before trial	Rule 95 entitles defense to statements of witnesses presented at initial hearings	Only required if the witness actually testified/was cross-examined	No error in denying production; not required until witness has testified (majority)
Compelled specification of State’s intended trial evidence	Defense argues for specification due to voluminous discovery	No such requirement under Puerto Rico criminal procedure	Denial of request upheld; falls within trial court’s discretion
Balancing need for digital discovery against privacy/intimacy	Defense's need overrides if material to defense	Prosecution stresses broad privacy rights in cell phone contents	Orders for extraction/discovery must weigh privacy, define scope, and set protective conditions

Riley v. California, 573 U.S. 373 (2014) (recognizes heightened privacy interest in cell phone contents)
Pueblo v. López Colón, 200 D.P.R. 273 (P.R. 2018) (applies Riley; establishes strong protection for digital evidence)
Pueblo v. Arzuaga, 160 D.P.R. 520 (P.R. 2003) (defines when defendant is entitled to witness statements)
Pueblo v. Sanders Cordero, 199 D.P.R. 827 (P.R. 2018) (standards for defense access to prosecution’s physical/digital evidence, limits of discovery)
Pueblo v. Vega, 148 D.P.R. 980 (P.R. 1999) (discretionary limits on discovery, not always dictated by party convenience)