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torttrialadmissibility
torttrialadmissibility

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Tydingco; U.S. v.

Facts

Lili Tydingco was convicted after a third trial for unlawfully harboring a noncitizen, X.N., in violation of 8 U.S.C. 1324(a)(1)(A)(iii). During her interview with Customs and Border Protection (CBP) Officer Ronald Muna, Tydingco's statements were translated by an interpreter. Tydingco argued that the interpreter's involvement and the admission of her signed statement violated her rights under the Confrontation Clause. The court had to determine the admissibility of the evidence presented during the trial.

Lili Tydingco was convicted after a third trial for unlawfully harboring a noncitizen, X.N., in violation of 8 U.S.C. 1324(a)(1)(A)(iii). During her interview with Customs and Border Protection (CBP) Officer Ronald Muna, Tydingco's statements were translated by an interpreter.

Issue

Did the admission of Tydingco's signed written statement and the interpreter's translation violate the Confrontation Clause?

Did the admission of Tydingco's signed written statement and the interpreter's translation violate the Confrontation Clause?

Rule

As long as a translator acts only as a language conduit, the use of the translator does not implicate the Confrontation Clause.

"[A]s long as a translator acts only as a language conduit, the use of the translator does not implicate the Confrontation Clause." United States v. Aifeng Ye, 808 F.3d 395, 401 (9th Cir. 2015).

Analysis

The court applied the rule by examining the role of the interpreter in Tydingco's case. It found that the interpreter had no motive to distort Tydingco's statements, as the same interpreter was used consistently throughout the process. Additionally, Tydingco's fluency in English meant she could have corrected any errors, which supported the conclusion that the interpreter's involvement did not violate her rights under the Confrontation Clause.

Here, the interpreter who translated Tydingco's statements had no motive to distort them; the same interpreter was used without issue both when Tydingco initially drafted her statement and when she returned to the police station to review it; and Tydingco identifies no particular translation errors the interpreter made. Additionally, as we explained in Tydingco II, Tydingco's English fluency means that she could have corrected any error the interpreter made.

Conclusion

The court affirmed Tydingco's conviction, concluding that the district court did not err in admitting her signed statement and that the interpreter acted only as a language conduit.

The court affirmed Tydingco's conviction, concluding that the district court did not err in admitting her signed statement and that the interpreter acted only as a language conduit.

Who won?

The United States prevailed in the case, as the court upheld Tydingco's conviction based on the admissibility of her statements and the role of the interpreter.

The United States prevailed in the case, as the court upheld Tydingco's conviction based on the admissibility of her statements and the role of the interpreter.

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