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People of the Territory of Guam v. Vincent T. Tedtaotao
Citations: 896 F.2d 371; 1990 U.S. App. LEXIS 1900; 1990 WL 11047Docket: 88-1054
Court: Court of Appeals for the Ninth Circuit; February 13, 1990; Federal Appellate Court
Vincent Tedtaotao appeals his convictions for murder, attempted murder, and use of a deadly weapon stemming from an incident at a nightclub in Guam on August 20, 1985. The Guam Superior Court indicted him for the murder of David Untalan, the attempted murder of Danny Camacho, and two counts of using a deadly weapon, which exposed him to enhanced sentencing under Guam law. During the trial, Tedtaotao claimed self-defense and sought to introduce evidence of Untalan's violent character to assert that Untalan was the initial aggressor. The prosecution moved to exclude this evidence, and the trial court granted the motion, reasoning that the prosecution's stipulation that Untalan was the initial aggressor rendered the character evidence unnecessary. The court also noted that Tedtaotao had no prior knowledge of Untalan's violent character, making it inadmissible to justify the reasonableness of his use of force. The jury convicted Tedtaotao on all charges, and the Appellate Division of the District Court affirmed the trial court's decision to exclude the character evidence, stating there was no error in that exclusion. Tedtaotao's appeal was reviewed for an abuse of discretion regarding evidence admission, with the Appellate Division's decision being examined de novo. The court concluded that while the character evidence was relevant, its probative value was diminished by the government's concession regarding Untalan's role as the initial aggressor, rendering the evidence cumulative and unnecessary. The probative value of character evidence regarding Untalan was deemed minimal and outweighed by multiple dangers: (i) unfair prejudice, as the jury might unduly focus on Untalan's character; (ii) confusion of issues, since the prosecution had conceded that Untalan was the initial aggressor, leading the jury to misinterpret the evidence as a means to judge Untalan rather than assess Tedtaotao's guilt; (iii) misleading the jury, potentially shifting their focus from Tedtaotao to Untalan; and (iv) unnecessary presentation of cumulative evidence, given the prior concession. The appeal by Tedtaotao centered solely on the character evidence's admission to establish Untalan as the first aggressor, and the court did not consider its admissibility concerning the reasonableness of the force used. The Appellate Division of the District Court of Guam had jurisdiction under 48 U.S.C. Sec. 1424-3(a), and the reviewing court had jurisdiction under 48 U.S.C. Sec. 1424-3(c). Additionally, Tedtaotao's late argument regarding the concession was waived, as it was raised for the first time in his reply brief, which is not typically reviewed.