Trujillo's trial was rendered fundamentally unfair due to the joint trial of unrelated charges and the admission of highly prejudicial gang evidence relevant to just three of the twelve substantive counts. When examining whether a joinder of charges rendered a trial fundamentally unfair, courts look at whether the evidence related to each charge would have been admissible in a separate trial of the jointly tried charges. Here, the evidence was not cross-admissible. This was particularly prejudicial given the gang enhancements alleged on three counts. Highly prejudicial and inflammatory gang testimony was admitted even though it would have been inadmissible in separate trials.

The Fourteenth Amendments' Due Process Clause guarantees the right to a fair trial. Did the Ninth Circuit's finding that Trujillo's Due Process rights were not violated by the joinder of unrelated charges so clearly misapply the law as to call for summary reversal?

Did the Ninth Circuit's finding that Trujillo's Due Process rights were not violated by the joinder of unrelated charges so clearly misapply the law as to call for summary reversal?