United States v. Juan Carlos Zuniga
6 F.3d 569 (1993)
Rule of Law:
A defendant is entitled to a specific jury instruction on their alibi defense if it is supported by law and has any foundation in the evidence, however weak or incredible. A trial court's failure to give such a requested instruction when there is evidentiary support is reversible error per se.
Facts:
- On April 19, 1991, at 5:45 p.m., the Valley National Bank in Phoenix, Arizona was robbed by a lone individual.
- Police traced the getaway car to Andres Gonzales Portal.
- Portal and another passenger, Damaso Olivera, told police they were with Juan Carlos Zuniga and that only Zuniga had entered the bank.
- The bank teller who was robbed later identified Zuniga from a photographic lineup.
- Police found a striped shirt in Zuniga's apartment similar to one worn by the robber.
- An officer testified that Zuniga identified himself in a bank surveillance photo, though this admission was not recorded or corroborated.
- At trial, Zuniga's wife, Tammi Woods, testified that Zuniga was at home with their baby when she returned from work on the day of the robbery.
- Woods testified that she arrived home between 5:15 p.m. and 6:00 p.m. at the latest.
Procedural Posture:
- The government charged Juan Carlos Zuniga with bank robbery in the United States District Court (the trial court).
- During the trial, Zuniga's defense counsel presented alibi testimony from Zuniga's wife.
- Defense counsel requested the court give the Ninth Circuit Model Jury Instruction on alibi.
- The district court refused to give the requested alibi instruction.
- The jury convicted Zuniga.
- Zuniga (appellant) appealed his conviction to the United States Court of Appeals for the Ninth Circuit, arguing the district court's refusal to give the instruction was reversible error.
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Issue:
Does a trial court commit reversible error by refusing to give a requested alibi jury instruction when the defendant has presented some evidence to support the alibi defense?
Opinions:
Majority - Pregerson, J.
Yes. A trial court commits reversible error by refusing to give a requested alibi jury instruction when the defendant presents any evidence supporting the defense. A defendant is entitled to an instruction on their theory of the case if it is supported by law and has some foundation in the evidence, even if that evidence is weak, insufficient, or of doubtful credibility. An alibi instruction is critical because jurors might otherwise incorrectly interpret a failure to prove the alibi as evidence of guilt. General instructions on the government's burden of proof and the presumption of innocence are not an adequate substitute for a specific alibi instruction, which clarifies that the burden always remains on the government to prove the defendant's presence at the scene of the crime. The failure to give such an instruction is reversible error per se and cannot be considered harmless.
Analysis:
This case solidifies the principle in the Ninth Circuit that a defendant's right to have the jury instructed on their theory of the case is fundamental. By classifying the failure to give a supported alibi instruction as reversible error per se, the court removes it from the more common 'harmless error' analysis. This holding creates a bright-line rule for trial courts: if any evidence of alibi is presented, the instruction must be given, or the conviction will be automatically overturned on appeal. This strengthens the protection for defendants, ensuring their primary defense is explicitly explained to the jury and that the burden of proof is not improperly shifted in the jurors' minds.
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