US v. Sandoval: Sandoval and his two codefendants were members of MS-13 charged with attempting to murder two people (along with related drug and racketeering activities). At trial, a cadre of translators operated so that the defendants and jury could understand proceedings (some of the witnesses were not English speakers). At one point, the district court received a note from a juror stating they were “completely fluent in Spanish and the translation was really poor today.” The district court made additional inquiries, but eventually denied the defendants’ motion for a mistrial due to translation errors.
On appeal, the Fourth Circuit affirmed the defendants convictions. Noting that the “basic constitutional inquiry” when it comes to problems with interpretation is “whether any inadequacy . . . made the trial fundamentally unfair,” the court concluded that the issues where did not. The court first held that issues here were not “structural” in that they did not “infect the entire trial process,” only portions of testimony on one day. The same lack of broad-scale error led to a conclusion that the trial was not fundamentally unfair, with the court concluding that the issue upon which there was some confusion was not “material to the jury’s guilty verdict on any count.” At bottom, there was no abuse of discretion in denying the request for a mistrial. The court also held that post-trial disclosure of a Government’s witness being investigated for malfeasance did not require a new trial, as the malfeasance involved was not the kind that called the witness’ credibility into question (and his testimony was broad testimony about the workings of MS-13, not the facts of the particular case).
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