United States v. Cesar Rosario Anguloa A/K/A Guadalupe Pedraza-Torres

Cesar Rosario Anguloa (Anguloa) was convicted of possession and importation of heroin with intent to distribute. He raises two issues on appeal: (1) denial of due process because of the Government’s actions in substituting interpreters, and (2) failure to establish the chain of custody to the heroin. We find no reversible error and affirm his conviction.

BACKGROUND

Anguloa, a Mexican national, was stopped while attempting to cross the border from Mexico to the United States at the San Luis Port of Entry. A search of his car revealed approximately 2271.7 grams of heroin hidden in the rocker panel to the car.

Difficulties developed at his trial because Anguloa neither speaks nor understands English. He was represented throughout the trial by privately retained counsel who did not speak Spanish and also by counsel from the Federal Public Defender’s office who did speak Spanish. The Assistant United States Attorney (referred to as prosecutor) did not speak Spanish, but a Spanish-speaking case agent assisted him during the trial. The trial judge, a visiting judge in the District of Arizona, also did not speak Spanish.

On the first day of trial, the regular court interpreter was ill…