Melvin Andrade v. United States
2014 D.C. App. LEXIS 97
D.C.2014Background
- A jury convicted Melvin Andrade of assault offenses and carrying a dangerous weapon.
- Andrade challenges the convictions on grounds of the prosecutor's interpreter-related comments and trial court interpretation protections.
- The trial court arranged interpreters; translation issues arose during testimony and were addressed by the court.
- The prosecutor cross-examined Andrade intensely and made closing-argument statements about his credibility.
- The court affirmed the convictions, finding no reversible error given corrective actions and overall record.
- The decision analyzes interpreter rights, prosecutorial conduct, and the trial court's handling of translation issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Prosecutor's comments about interpreter use | Andrade argues comments disparaged testimony and rights. | Court should curb prosecutorial personal judgments on veracity. | Not reversible error; prosecution comments exceeded bounds but no substantial prejudice. |
| Questions about attorney discussions | Cross-exam questions about discussions with counsel were improper. | Such inquiries unfairly intrude on defense strategy. | Not reversible; objections and trial-court handling mitigated prejudice. |
| Prosecutor's closing on credibility | Closing emphasized defendant’s purported lack of truthfulness. | Closing improperly urged negative inferences about Andrade. | Not reversible; total impact not shown to substantially prejudice. |
| Trial court's interpreter protections | Court failed to safeguard Andrade's interpreter right. | Interpreters and corrective actions were insufficient. | Court acted appropriately; steps ensured meaningful access and understanding. |
Key Cases Cited
- Diaz v. United States, 716 A.2d 173 (D.C. 1998) (prosecutor cannot express personal opinion on credibility)
- Ball v. United States, 26 A.3d 764 (D.C. 2011) (plain-error standard when no objection to improper comment)
- Fox v. United States, 11 A.3d 1282 (D.C. 2011) (substantial prejudice requires gravity, relation to guilt, and corrective instructions)
- Ramirez v. United States, 877 A.2d 1040 (D.C. 2005) (translation access and fairness when defendant language-impaired)
- Gonzalez v. United States, 697 A.2d 819 (D.C. 1997) (trial court's role in interpreter competence)