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United States v. Catalan-Roman

United States Court of Appeals for the First Circuit
585 F.3d 453 (2009)


Facts

The United States government (plaintiff) prosecuted Lorenzo Catalan-Roman (Catalan) and Hernando Medina-Villegas (Medina) (defendants) on several counts in connection with an armored car robbery. The robbery led to the murder of one of the armored car's guards, Gilberto Rodriguez-Cabrera (Rodriguez), and the government sought the death penalty for that crime. Eluber Torres-Alejandro (Torres), the armored car's driver, was wounded in the incident. Police briefly interviewed Torres while he received hospital treatment for his wounds. At trial, Torres gave aggravating details of the murder that he had omitted during his hospital interview. The details showed Medina acted with premeditation when he killed Rodriguez. The defense attempted to introduce the hospital interview as evidence, arguing the aggravating details were so integral to any account of the incident that their absence from the hospital interview could indicate Torres fabricated the details later. The judge excluded the interview as extrinsic evidence of a collateral matter unrelated to whether Medina was the killer. The jury convicted Catalan and Medina, and the judge sentenced them to life in prison without the possibility of parole. On appeal to the United States Court of Appeals for the First Circuit, they argued the judge erred in excluding the hospital interview from evidence.

Rule of Law

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Issue

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Holding and Reasoning (Lipez, J.)

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  • A “yes” or “no” answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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