United States v. Oscar Rodriguez
766 F.3d 970
| 9th Cir. | 2014Background
- Rodriguez, Murillo, and Mujica were convicted of conspiracy to commit murder and first‑degree murder for stabbing inmate Peter Scopazzi at USP Victorville; others charged included Martinez and Meneses.
- Government alleged motive rooted in prison gang (Sureños) culture and ties to the Mexican Mafia; evidence included a note (kite) from Murillo and expert testimony about gang hierarchy.
- Defense sought to introduce expert medical testimony that negligent hospital care and removal of a breathing tube contributed to Scopazzi’s death; district court limited testimony to wound characteristics and excluded negligence/causation testimony.
- Defense challenged admission of evidence about the Mexican Mafia; district court admitted limited gang affiliation evidence and photos, declining to give its offered limiting instruction when defendants refused it.
- Key government witness Ryan Davis testified about the assault and acknowledged possible benefits from cooperation; defense later moved for a new trial alleging Brady/Giglio/Mooney–Napue violations based on undisclosed leniency and informant status—motion denied.
Issues
| Issue | Plaintiff's Argument (Appellants) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Exclusion of medical‑negligence evidence | Excluding evidence that gross medical negligence or tube removal caused death deprived them of a complete defense and negated proximate cause/intent | Medical negligence was not shown to be a superseding cause; evidence irrelevant or confusing; proximate cause from stab wounds established | Affirmed: exclusion harmless; defendants failed to proffer evidence that medical care was extraordinary sole cause; proximate cause foreseeable from stabbings |
| Admission of Mexican Mafia/Sureños evidence | Gang/Mafia evidence irrelevant and unduly prejudicial because appellants were not Mexican Mafia members | Evidence relevant to motive and planning; limited admission and jury voir dire mitigated prejudice | Affirmed: evidence admissible as motive; probative value > prejudice; court acted within discretion |
| Brady/Giglio: undisclosed tacit leniency agreement with Davis | Government failed to disclose a tacit promise to seek sentence reduction for Davis, which would impeach his testimony and require a new trial | No undisclosed tacit agreement shown; Davis testified about possible benefits and signed a letter agreement; government disclosed letter and interviews | Affirmed: no Brady violation; no evidence of tacit promise; temporal proximity of Rule 35 filing insufficient |
| Mooney–Napue: failure to correct allegedly false testimony by Davis | Davis falsely denied expectation of leniency; government knew or should have known and failed to correct, warranting new trial | No evidence Davis’s testimony was actually false or that prosecution knew it was false; post‑verdict actions consistent with disclosed agreement | Affirmed: defendants did not satisfy elements; not entitled to new trial |
Key Cases Cited
- Pineda‑Doval v. United States, 614 F.3d 1019 (9th Cir. 2010) (proximate‑cause analysis: foreseeable intervening responses do not break causation chain)
- Brackett v. Peters, 11 F.3d 78 (7th Cir. 1993) (assailant liable where medical complications only one of multiple causes; solitary medical malpractice must be sole cause to relieve liability)
- United States v. Swallow, 109 F.3d 656 (10th Cir. 1997) (medical/rescue negligence typically does not absolve assailant of homicide)
- United States v. Guillette, 547 F.2d 743 (2d Cir. 1976) (proximate cause includes foreseeable intervening events that naturally flow from the defendant’s conduct)
- United States v. Main, 113 F.3d 1046 (9th Cir. 1997) (requirement to instruct jury on proximate cause where foreseeability is in dispute; distinguishable where conduct creates obvious lethal risk)
- United States v. Santiago, 46 F.3d 885 (9th Cir. 1995) (admission of gang/Mexican Mafia evidence to prove motive permissible)
- Dawson v. Delaware, 503 U.S. 159 (1992) (associational rights limit gang evidence when unrelated to charged offense)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose favorable, material evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (impeachment material from plea/leniency deals must be disclosed)
- Napue v. Illinois, 360 U.S. 264 (1959) (conviction obtained by false testimony violates due process)
- Mooney v. Holohan, 294 U.S. 103 (1935) (prosecution must not use perjured testimony)
- United States v. Si, 343 F.3d 1116 (9th Cir. 2003) (informant reports can be impeachment material)
- United States v. Houston, 648 F.3d 806 (9th Cir. 2011) (standards for Napue/Mooney claims and materiality)