State of Arizona v. Crispin Granados
235 Ariz. 321
| Ariz. Ct. App. | 2014Background
- Victim P.L., ~72, was grabbed, beaten, taken into her home, and sexually assaulted multiple times by Crispin Granados in Sept. 2010; Granados held her in the home for ~2–3 days, threatened her and family, and prevented communication or food.
- P.L. escaped when Granados allowed her to attend a doctor’s appointment; she then reported the crimes to police.
- Granados was convicted by a jury of kidnapping, second-degree burglary, two counts of sexual assault, aggravated assault, and aggravated harassment and sentenced to a total of 20 years’ imprisonment.
- On appeal Granados challenged (1) judicial bias based on the trial judge’s courtroom removals, admonishments, and evidentiary rulings, and (2) admission of hearsay elicited through rebuttal testimony.
- The trial judge removed Granados from the courtroom during voir dire for disruptive behavior, repeatedly admonished him for nonresponsive testimony, and at times intervened sua sponte to stop inadmissible testimony; the defense did not file a Rule 10.1 recusal motion.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Granados) | Held |
|---|---|---|---|
| Judicial bias / appearance of bias | Judge acted within duty to control courtroom; rulings and removals were proper | Removal from courtroom, sustaining numerous objections, and sua sponte interventions created an appearance of bias and warrant structural-error review | Court: No structural error; defense alleged only judicial rulings/behavior not extrajudicial or pecuniary interest; claim forfeited for lack of Rule 10.1 motion and does not show bias |
| Recusal standard / structural error | Structural error requires extreme grounds (e.g., direct pecuniary interest or comparable extraordinary facts) | Argued appearance-of-bias based on judge’s conduct suffices for structural-error review | Court: Applies Tumey/Caperton standard; ordinary judicial rulings or admonishments do not meet that high constitutional threshold |
| Sua sponte courtroom control | Court may act sua sponte to prevent inadmissible testimony and must control the trial | Sua sponte interruptions (including cutting off interpreter) biased jury against defendant | Court: Sua sponte interventions were within discretion to prevent inadmissible evidence and did not show deep-seated antagonism |
| Admission of hearsay (police officer’s recounting of victim’s prior statements) | Admitted to rebut inference defense opened on cross-examination (invited error/open-door doctrine) | Admission of hearsay improperly prejudiced Granados | Court: Admission proper under invited-error doctrine (and, if erroneous, cumulative and harmless) |
Key Cases Cited
- Ring v. Arizona, 204 Ariz. 534 (discusses structural error and biased trial judge)
- Tumey v. Ohio, 273 U.S. 510 (1927) (judicial bias constituting structural due-process defect when judge has direct, personal, substantial pecuniary interest)
- Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009) (recusal required only in rare, extreme circumstances creating unconstitutional probability of bias)
- Liteky v. United States, 510 U.S. 540 (1994) (judicial rulings alone almost never constitute bias grounds)
- Bible v. State, 175 Ariz. 549 (1993) (trial judge must control courtroom; sua sponte action permissible to prevent inadmissible evidence)
- Kemp v. State, 185 Ariz. 52 (1996) (invited-error/open-door doctrine allows hearsay rebuttal when defense cross-examination creates improper inference)