abuse of discretion standard in Guam

2026“An abuse of discretion results where the sentence ‘is based on an erroneous conclusion of law or where the record contains no evidence on which the judge could have rationally based the decision.’” People v. Manila, 2018 Guam 24 ¶ 17 (quoting People v. Manibusan, 2016 Guam 40 ¶ 12). [24] “Issues of statutory interpretation are reviewed de novo.” People v. Joshua, 2015 Guam 32 ¶ 20 (quoting People v. Felder, 2012 Guam 8 ¶ 9).

2022“Plain error is highly prejudicial error, which this court ‘will not reverse unless (1) there was an error; (2) the error is clear or obvious under current law; (3) the error affected substantial rights; and (4) reversal is necessary to prevent a miscarriage of justice or to maintain the integrity of the judicial process.’” Gargarita, 2015 Guam 28 ¶ 11 (quoting Felder, 2012 Guam 8 ¶ 19). [73] As Bosi briefed these issues under the abuse of discretion standard, his argument does not graft well onto the plain error standard.

2025The trial court’s decision is entitled to deference under the abuse of discretion standard of review [77] When reviewing a trial court’s denial of a motion for a new trial under the abuse of discretion standard, “this court will not simply ‘substitute its judgment for that of the trial court.’” Bosi, 2022 Guam 15 ¶ 71 (citation omitted).

2021People v. Perez, 2015 Guam 10 ¶ 19. “[A] trial court’s decision concerning the admission of evidence over a hearsay objection is reviewed under an abuse of discretion standard.” People v. Roten, 2012 Guam 3 ¶ 13. “[W]here the trial court has abused its discretion in admitting certain evidence, the proper standard for evaluating whether reversal is required is the harmless error standard.” Id. ¶ 41. [21] Plain errors affecting substantial rights may be noticed even though they were not brought to the attention of the court.

2026“An abuse of discretion results where the sentence ‘is based on an erroneous conclusion of law or where the record contains no evidence on which the judge could have rationally based the decision.’” People v. Manila, 2018 Guam 24 ¶ 17 (quoting People v. Manibusan, 2016 Guam 40 ¶ 12). [24] “Issues of statutory interpretation are reviewed de novo.” People v. Joshua, 2015 Guam 32 ¶ 20 (quoting People v. Felder, 2012 Guam 8 ¶ 9).

2026“An abuse of discretion results where the sentence ‘is based on an erroneous conclusion of law or where the record contains no evidence on which the judge could have rationally based the decision.’” People v. Manila, 2018 Guam 24 ¶ 17 (quoting People v. Manibusan, 2016 Guam 40 ¶ 12). [24] “Issues of statutory interpretation are reviewed de novo.” People v. Joshua, 2015 Guam 32 ¶ 20 (quoting People v. Felder, 2012 Guam 8 ¶ 9).

2025See id. (“Little turns, however, on whether we label review of this particular question abuse of discretion or de novo, for an abuse-of-discretion standard does not mean a mistake of law is beyond appellate correction.”). 1.

2025People v. Messier, 2014 Guam 34 ¶ 11 (citing People v. Quinata, 1999 Guam 6 ¶ 16); People v. Leslie, 2011 Guam 23 ¶ 12. [30] The abuse of discretion standard is a “highly deferential” standard of review.

2025People v. Messier, 2014 Guam 34 ¶ 11 (citing People v. Quinata, 1999 Guam 6 ¶ 16); People v. Leslie, 2011 Guam 23 ¶ 12. [30] The abuse of discretion standard is a “highly deferential” standard of review.

2025“But under the abuse-of-discretion standard, we cannot substitute our judgment for that of the trial court.” Lujan v. Tebo, 2024 Guam 15 ¶ 32 (per curiam) (citing People v. Quintanilla, 2001 Guam 12 ¶ 9).

2024STANDARD OF REVIEW [14] “[A] trial court’s decision concerning the admission of evidence over a hearsay objection is reviewed under an abuse of discretion standard.” People v. Tedtaotao, 2016 Guam 9 ¶ 10 (quoting People v. Roten, 2012 Guam 3 ¶ 13).