Martinez Santoyo v. Boyden
24-1967
9th Cir.Mar 11, 2025Background
- Jose Trinidad Martinez Santoyo appealed the denial of his habeas corpus petition concerning his extradition to Mexico.
- He challenged an extradition court’s order certifying his extradition for intentional aggravated homicide with advantage.
- Santoyo argued lack of probable cause for his extradition, the improper exclusion of a forensic report, and the denial of a motion to compel discovery from a prior unrelated case against the decedent.
- Three eyewitnesses testified that Santoyo shot the decedent twice in the head; physical evidence and the autopsy were consistent with this account.
- The extradition court found probable cause and refused Santoyo’s requests to introduce a forensic report and for additional discovery.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause | No reasonable grounds given conflicting forensic evidence. | Eyewitness evidence and physical findings established probable cause. | Probable cause found; affirming extradition. |
| Admission of forensic report | Forensic report (gunpowder residue) should be admitted to negate probable cause. | Report is only contradictory, not obliterative of probable cause. | Exclusion upheld; report was merely contradictory evidence. |
| Motion to compel discovery | Entitled to info from decedent’s unrelated prior case. | Discovery in extradition limited; information not relevant or admissible. | Denial of discovery motion affirmed. |
| Treaty lapse of time/Speedy Trial Clause | Treaty incorporates Sixth Amendment rights. | Treaty does not incorporate the Speedy Trial Clause in extradition. | Addressed in concurrent opinion, affirmed lower court. |
Key Cases Cited
- Rana v. Jenkins, 113 F.4th 1058 (9th Cir. 2024) (articulates standard of review for habeas petition in extradition)
- Santos v. Thomas, 830 F.3d 987 (9th Cir. 2016) (explains court's broad discretion in extradition evidentiary rulings)
- Prasoprat v. Benov, 421 F.3d 1009 (9th Cir. 2005) (addresses limits on discovery in international extradition)
- Oen Yin-Choy v. Robinson, 858 F.2d 1400 (9th Cir. 1988) (sets standard for finding probable cause in extradition)
- Merino v. U.S. Marshal, 326 F.2d 5 (9th Cir. 1963) (declines to apply Brady discovery in extradition context)