People of the Territory of Guam v. Anthony Camacho Ignacio
Opinion
Opinion
Nelson, J.
Anthony Camacho Ignacio (“Ignacio”) appeals from a ruling of the District Court of Guam, Appellate Division affirming his jury conviction for first degree criminal sexual conduct. The jury found that Ignacio had sexually molested a three-year-old girl, and the court sentenced him to seven years imprisonment. We have jurisdiction under 48 U.S.C. § 1424-3 (c).
Ignacio makes three claims on appeal: (1) that the court’s admission of certain hearsay statements violated the Confrontation Clause; (2) that the court erred in excluding evidence about a defense theory of third-party culpability; and (3) that the evidence was insufficient to support the conviction. We find that three of the four hearsay statements to which Ignacio objects were properly admitted. With respect to the fourth, the victim’s statements to a social worker, we hold that they were not admissible under the medical diagnosis or treatment exception. In this case, however, the admission of such evidence was harmless beyond a reasonable doubt. None of the other claims has merit. Accordingly, we affirm the conviction.