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Haraguchi v. Superior Court, 43 Cal.4th 706, 182 P.3d 579, 76 Cal.Rptr.3d 250, 08 Cal. Daily Op. Serv. 5649, 2008 Daily Journal D.A.R. 6779

Facts

Defendant Haraguchi was charged with the rape of an intoxicated person and moved for the recusal of Deputy District Attorney Joyce Dudley, citing her recent publication of a novel that he argued was related to his case. Haraguchi claimed that the novel contained a fictional account of a similar crime and that Dudley's promotion of the book influenced her handling of his case. The trial court denied the motion, finding no conflict, but the Court of Appeal initially granted the petition for recusal, leading to the Supreme Court's review.

On April 25, 2006, Haraguchi moved for recusal of Deputy District Attorney Joyce Dudley and the Santa Barbara County District Attorney's Office based on Dudley's publication of a novel, Intoxicating Agent, in January 2006, as well as her subsequent promotion of the book. Haraguchi alleged, inter alia, that (1) the book contained a lengthy fictional account of the rape of an intoxicated person; (2) the fictional trial, like Haraguchi's, was to begin around April 2006; (3) a character in Dudley's novel bore a resemblance to Haraguchi; and (4) the facts of the fictional rape in other respects mirrored another unrelated case in which Dudley had obtained only a hung jury.

Issue

Whether Deputy District Attorney Joyce Dudley's publication of a novel created a conflict of interest that warranted her recusal from prosecuting Haraguchi's case.

Whether Deputy District Attorney Joyce Dudley's publication of a novel created a conflict of interest that warranted her recusal from prosecuting Haraguchi's case.

Rule

A motion to recuse a prosecutor may not be granted unless the evidence shows that a conflict of interest exists that would render it unlikely that the defendant would receive a fair trial.

A motion to recuse a prosecutor may not be granted unless the evidence shows that a conflict of interest exists that would render it unlikely that the defendant would receive a fair trial.

Analysis

The Supreme Court applied the two-part test for recusal, first determining that no conflict existed between Dudley's novel and Haraguchi's case. The court found that the novel was not factually based on the case and that any perceived similarities were coincidental. Furthermore, the court concluded that Dudley's views as expressed in the novel did not reflect a bias that would compromise her ability to prosecute fairly.

The trial court concluded there was no “conflict that would justify recusal of Ms. Dudley.” It based that conclusion on a series of factual findings: “The publication of her book appears to be coincidental to Mr. Haraguchi's circumstances. The circumstances related in her book factually don't appear to relate to Mr. Haraguchi's circumstances, and the fact that there may be similarities to some other case that Ms. Dudley tried in the past doesn't establish any conflict as far as Mr. Haraguchi's case is concerned.

Conclusion

The Supreme Court reversed the Court of Appeal's decision, holding that there was no basis for recusal and that Haraguchi had not demonstrated a likelihood of an unfair trial.

For the foregoing reasons, we reverse the Court of Appeal's judgment and remand this case for further proceedings consistent with this opinion.

Who won?

The prevailing party was Deputy District Attorney Joyce Dudley, as the Supreme Court found no conflict of interest that would necessitate her recusal.

The Supreme Court reversed the Court of Appeal's decision, holding that there was no basis for recusal and that Haraguchi had not demonstrated a likelihood of an unfair trial.

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