1. Introduction

In People of Guam v. Duayne Richard Peters, the Supreme Court of Guam was asked to review a host of challenges following Peters’s conviction for multiple counts of first- and second-degree criminal sexual conduct (CSC) and vulnerable-victim enhancements. The case arises from the prosecution of Peters and his wife, N.P., for sexual abuse of a minor relative. Critical to the appeal was N.P.’s plea agreement: she secured a time-served sentence in exchange for “truthful” testimony against Peters. Peters contended that the agreement coerced her to testify in a predetermined manner and therefore violated his right to due process and a fair trial. He also alleged ineffective assistance of counsel over late-disclosed victim journals.

The Supreme Court affirmed the conviction but, in doing so, articulated significant clarifications on (i) the difference between traditional (constitutional) standing and contractual standing when a non-party seeks to invalidate a plea agreement; (ii) the distinction between waiver and forfeiture and their effect on appellate review; and (iii) the procedural safeguards that insulate accomplice testimony obtained through plea bargains. Additionally, the Court reiterated that ineffective-assistance claims usually belong in post-conviction habeas proceedings when the trial record is inadequate.

2. Summary of the Judgment

• Standing / Plea Agreement. The Court declined to invalidate N.P.’s plea bargain, holding that Peters neither demonstrated any illegal consideration nor showed the agreement compelled perjured testimony. Even assuming Peters possessed “contractual standing,” he failed to meet the four-prong plain-error test.
• Fair-Trial Claim. Applying precedent (notably United States v. Dailey), the Court found the jury was fully apprised of the plea’s terms, defense counsel cross-examined N.P., and the court instructed the jury on bias—adequate safeguards against coerced testimony.
• Ineffective Assistance. Claims regarding counsel’s handling of victim journals require fact-finding beyond the appellate record; the Court directed such claims to be raised (if at all) via habeas corpus.
• Result. Convictions and 30-year sentence affirmed.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

1. People v. Tedtaotao (2023 Guam 21) – Confirmed that contract principles apply to plea agreements and authorized judicial notice of related filings.
2. People v. Santos (2021 Guam 12) – Clarified waiver vs. forfeiture; supplied the plain-error framework used here.
3. People v. Mendiola (2023 Guam 12) – Restated the four-factor plain-error test.
4. People v. Manley (2010 Guam 15) – Held that unpreserved guilty-plea challenges are judged under plain error.
5. United States v. Dailey, 759 F.2d 192 (1st Cir. 1985) – Set out “established safeguards” for accomplice testimony via plea bargains.
6. People v. Allen, 729 P.2d 115 (Cal. 1986) & People v. Homick, 289 P.3d 791 (Cal. 2012) – Distinguished between plea terms that require “truthful” testimony (permissible) and those demanding specific narrative conformity (impermissible).
7. Federal and state authorities on traditional vs. contractual standing (e.g., SM Kids, LLC v. Google LLC, 963 F.3d 206 (2d Cir. 2020)). These informed the Court’s analytical framework.

3.2 The Court’s Legal Reasoning

a. Traditional vs. Contractual Standing

The Court first drew a sharp line between jurisdictional “traditional” standing (rooted in Article III analogues) and “contractual” standing (a merits inquiry into who may sue on a contract). While a criminal defendant plainly has standing to raise constitutional objections (due process), he may lack contractual standing to enforce or void another person’s plea bargain unless he can show the contract is void as against public policy. The Court assumed arguendo that Peters had such standing but found no illegal consideration or public-policy violation.

b. Plain-Error Review

Because defense counsel failed to object at trial, Peters’s objections were forfeited, not waived. Under Mendiola, reversal requires: (1) error; (2) clear/obviousness; (3) impact on substantial rights; (4) miscarriage-of-justice requirement. The Court found no error, ending the analysis at step 1.

c. Validity of the Plea Agreement

A plea’s leniency alone does not invalidate it. The facilitation statute (9 GCA §4.65) expressly permits a third-degree felony plea. Crucially, the agreement obligated N.P. only to “testify truthfully,” not to incriminate Peters regardless of her perception of truth. Absent an express requirement to secure conviction or recite a specific narrative, the contract was not “tainted beyond redemption.”

d. Fair-Trial Safeguards

Applying Dailey’s triad of safeguards — disclosure, cross-examination, cautionary instruction — the Court held the risk of perjury was adequately mitigated. Any credibility determination remained for the jury.

e. Ineffective Assistance of Counsel

Under Strickland v. Washington, ineffective-assistance claims often need extra-record development. The Court found the appellate record silent on (i) counsel’s investigation efforts, (ii) contents of the journals, and (iii) any prejudice. Hence, habeas corpus is the appropriate vehicle.

3.3 Potential Impact of the Decision

• Plea-Bargain Drafting & Enforcement. Prosecutors must continue to anchor cooperation clauses to truthfulness. Any language hinting at mandated conviction risks invalidation.
• Defense Strategy. Defendants wishing to challenge co-defendant deals must object contemporaneously, articulate the specific illegality, and build a record; failure relegates them to plain-error hurdles.
• Standing Doctrine. Guam now explicitly imports the “contractual standing” concept into criminal-procedure analysis, offering a structured roadmap for future litigants.
• Waiver vs. Forfeiture Clarified. The decision re-emphasises precise usage, curbing over-broad “waiver” arguments by the prosecution and guiding trial courts on review standards.
• Post-Conviction Litigation. The Court’s reminder that ineffective-assistance claims usually belong in habeas proceedings will likely channel such claims away from direct appeals, fostering more fulsome factual records.

4. Complex Concepts Simplified

Traditional (Constitutional) Standing

The power of a court to hear a case — generally requiring an injury-in-fact, causation, and redressability.

Contractual Standing

Whether a litigant is a party, assignee, or intended beneficiary entitled to enforce (or void) a contract; it goes to the merits, not jurisdiction.

Plea Agreement

A contract between prosecutor and defendant where the latter pleads guilty/cooperates in exchange for concessions (reduced charges, sentencing recommendations, immunity).

Plain-Error Review

An appellate standard triggered when no contemporaneous objection was made; the appellant must show (1) error, (2) obviousness, (3) effect on substantial rights, and (4) that reversal is needed to prevent miscarriage of justice or preserve integrity.

Waiver vs. Forfeiture

Waiver: intentional relinquishment of a known right (issue unreviewable). Forfeiture: failure to timely assert right (issue reviewable for plain error).

Brady Material

Evidence favorable to the accused that is material either to guilt or punishment; suppression violates due process (Brady v. Maryland).

5. Conclusion

People v. Peters meaningfully clarifies Guam law in three areas:

1. It distinguishes contractual standing from the jurisdictional standing inquiry and sets parameters for when a defendant may challenge a co-defendant’s plea agreement.
2. It reinforces the analytical separation between waiver and forfeiture, cementing plain-error review for the latter.
3. It reaffirms that accomplice plea agreements conditioned on truthful testimony, accompanied by disclosure, cross-examination, and jury instruction, do not inherently violate due process.

For practitioners, the case underscores the necessity of timely objections and precise record-making to avoid the high bar of plain-error review, while also offering guidance on how to draft and scrutinize cooperation agreements. For the judiciary, it supplies a structured approach to evaluate third-party challenges to plea bargains and to channel ineffective-assistance claims to collateral review where a robust factual record can be compiled.