United States v. Stuart Seugasala
702 F. App'x 572
| 9th Cir. | 2017Background
- Stuart T. Seugasala was convicted after a jury trial of conspiracy to distribute controlled substances, kidnapping, using firearms in furtherance of drug conspiracy and kidnapping, and unauthorized disclosure of health information. He appealed and the Ninth Circuit affirmed.
- The case involved forcible removal (asportation) of kidnapping victims from an apartment to a strip club, denial of medical care, and related drug- and firearm-related conduct; evidence included victim testimony, accomplice testimony, video, and cell-phone data.
- Pretrial litigation included Seugasala’s late request to represent himself on the eve of trial and earlier requests for substitute counsel; the district court found the requests were delay tactics.
- Seugasala challenged grand-jury composition, arguing Pacific Islanders were underrepresented in the grand-jury pool.
- Multiple Fourth Amendment and evidence challenges were litigated: legality/length of a traffic stop, warrantless searches under supervised-release conditions, admission of cell-phone download evidence without expert testimony, and admission of a video and evidence about a separate shooting incident.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Right to self-representation (Faretta) | Government: district court acted within discretion in denying pro se request when made to delay trial | Seugasala: he unequivocally invoked Faretta and should have been permitted to proceed pro se | Court: request was equivocal and, even if unequivocal, district court reasonably found it was made for delay; no Faretta violation |
| Grand-jury fair-cross-section challenge | Government: grand jury pool not substantially deficient for Pacific Islanders | Seugasala: Pacific Islanders are a distinctive group and underrepresented in the grand jury pool | Court: disparity (~0.5%) too small and defendant failed to show systematic exclusion; challenge denied |
| Kidnapping (asportation) sufficiency | Government: movements from apartment to strip club and denial of leaving/hospital satisfy kidnapping elements | Seugasala: asportation was incidental to assault, so kidnapping convictions improper | Court: asportation was more than incidental; kidnapping convictions upheld |
| Admissibility of evidence from traffic stop and searches | Government: stop and probation-related searches were lawful; device seizures and forensic searches were authorized by supervision terms and supported by reasonable suspicion/warrants | Seugasala: stop was unlawfully prolonged; searches/forensic device exams required suppression; cellphone downloads required expert foundation; Denny’s-shooting evidence prejudicial | Court: no plain error—stop not clearly prolonged and probation officer had reasonable suspicion; searches authorized by supervision and warranted; Cellebrite/XRY operator testimony was lay, not expert; Denny’s evidence admissible and severance waived; any video error harmless |
Key Cases Cited
- Faretta v. California, 422 U.S. 806 (1975) ( Sixth Amendment right to self-representation )
- United States v. George, 56 F.3d 1078 (9th Cir. 1995) (late pro se requests may be denied when made for delay)
- United States v. Kaczynski, 239 F.3d 1108 (9th Cir. 2001) (complexity and timing of pro se request affect fairness and delay concerns)
- United States v. Hernandez-Estrada, 749 F.3d 1154 (9th Cir. 2014) (standards for fair-cross-section grand-jury claims)
- Rodriguez v. United States, 135 S. Ct. 1609 (2015) (unlawful prolongation of traffic stops requires reasonable suspicion)
- United States v. Waters, 627 F.3d 345 (9th Cir. 2010) (harmless-error standard for admission of evidence)
- United States v. Moran, 493 F.3d 1002 (9th Cir. 2007) (co-conspirator statements admissibility)
- United States v. Heuer, 4 F.3d 723 (9th Cir. 1993) (severance and waiver principles)