A trial court's denial of a statutory speedy trial claim is reviewed for an abuse of discretion. People v. Flores, 2009 Guam 22 ¶ 9. We also review the trial court's admission of prior bad acts under GRE 404(b) for abuse of discretion.
"The test for harmless error is whether it appears beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." People v. Flores, 2009 Guam 22 ¶ 112 (quoting Neder v. United States, 527 U.S. 1, 15, 119 S. Ct. 1827, 144 L. Ed. 2d 35 (1999)) (internal quotation marks omitted). The People are correct in the assertion that the testimony revealed the fact of felony release to the jury.
We thus decline to address whether Smith enjoys separate immunity under 19 GCA § 2105, as it would not be necessary to a resolution of the issue. See Hemlani v. Hemlani, 2015 Guam 16 ¶ 33; People v. Flores, 2009 Guam 22 ¶ 85. Accordingly, we find that the actions taken by Smith appropriately satisfied petitioning to trigger the protections of the Guam CPGA.