People v. Chagoya CA5, F087422

Alejandro Eliuth Chagoya was convicted by a jury of robbery and five counts of assault with a firearm on a peace officer related to a November 2020 incident in Bakersfield, CA, involving an altercation that escalated into a police chase and exchange of gunfire.
The prosecution also introduced testimony that, while in custody in July 2021, Chagoya made statements about trying to kill police officers, which he contested should have been excluded due to possible discovery violations regarding unavailable video evidence.
The jury acquitted Chagoya of kidnapping, carjacking, and attempted murder charges but convicted him of robbery and assault, with enhancements for firearm use on most counts, leading to a sentence of over 61 years.
Chagoya challenged the admission of his in-custody statements about intent, the refusal to give a jury instruction on untimely evidence disclosure, the expert toolmark (ballistics) testimony linking him to shell casings, and argued for cumulative error.
The Court of Appeal affirmed the trial court’s rulings and the judgment.

Issue	Chagoya's Argument	State's Argument	Held
Admission of in-custody statement (discovery issue)	Prosecutor failed to timely disclose/explore possible video; should exclude testimony.	Prosecutor didn’t willfully withhold evidence; disclosure was timely; sought video once aware.	No abuse; exclusion not warranted without willful violation or prejudice.
CALCRIM No. 306 jury instruction (untimely evidence)	Instruction required due to prosecutor’s failure regarding video.	No prejudicial violation; reports were timely disclosed; defense could argue missing video.	Instruction not warranted; any error was harmless.
Admission of toolmark (ballistics) expert testimony	Testimony too subjective, not based on sufficient standards; should be excluded.	Toolmark analysis is generally accepted; defense could cross-examine expert.	No error/harm; exclusion not required under applicable standards.
Cumulative error	Combined errors denied fair trial.	No errors or only harmless errors; verdict supported by strong evidence.	No prejudicial errors to aggregate; conviction stands.

People v. Ayala, 23 Cal.4th 225 (Cal. 2000) (Discovery sanctions and abuse of discretion standard)
People v. Chance, 44 Cal.4th 1164 (Cal. 2008) (Assault focuses on act, not specific intent to injure)
People v. Williams, 26 Cal.4th 779 (Cal. 2001) (Assault is a general intent crime, not requiring specific intent)
People v. Sargon Enterprises, Inc. v. University of S. Cal., 55 Cal.4th 747 (Cal. 2012) (Trial court’s gatekeeping role for expert testimony)
People v. Azcona, 58 Cal.App.5th 504 (Cal. Ct. App. 2020) (Limits of toolmark expert testimony)
People v. Watson, 46 Cal.2d 818 (Cal. 1956) (Harmless error standard for prejudice)