The Supreme Court of Guam has vacated the convictions of William Robert Reyes and ordered a new trial after finding the trial court abused its discretion in denying his motion for a mistrial. The decision, issued Thursday in People v. Reyes, 2025 Guam 8, was authored by Chief Justice Robert J. Torres and joined by Associate Justices F. Philip Carbullido and Katherine A. Maraman.
Reyes had appealed his convictions for first- and second-degree criminal sexual conduct, challenging the denial of both a mistrial motion and a motion for judgment of acquittal on the first-degree charge. The high court upheld the trial court’s denial of the acquittal motion, ruling that sufficient evidence existed for a rational jury to find that sexual penetration occurred based on the victim’s testimony.
However, the Supreme Court found error in the trial court’s decision to allow prosecutors to cross-examine Reyes about a decades-old arrest and indictment involving alleged crimes against minors that did not result in convictions. The court ruled that Guam Rule of Evidence 609 applies only to prior convictions and that the trial court relied on an incorrect legal basis.
The justices concluded the error was not harmless, finding the court could not determine it was more probable than not that the improperly admitted evidence did not affect the jury’s verdict. As a result, Reyes’s convictions were vacated and the case was remanded for a new trial.