Justia Criminal Law Opinion Summaries

Articles Posted in New Mexico Supreme Court
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Defendant Anthony Blas Yepez was convicted of, among other crimes, second-degree murder. At issue before the New Mexico Supreme Court was the district court’s exclusion of proposed expert testimony concerning Yepez’s alleged genetic predisposition to impulsive violence: testimony Yepez offered on the issue of whether he had the deliberate intent to kill. The Supreme Court held that the district court did not abuse its discretion by excluding the testimony. Accordingly, the Court reversed the Court of Appeals’ holding on this issue, rejected Yepez’s cross-appeal, and affirmed his conviction. View "New Mexico v. Yepez" on Justia Law

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Defendant Lorenzo Martinez appealed his convictions for first- degree murder and third-degree criminal sexual penetration (CSP) of the victim (Victim) after she died. Defendant challenged his convictions on multiple grounds, most of which were controlled by precedent. However, the New Mexico Supreme Court reviewed one argument as a matter of first impression: whether a decedent constituted a “person” as that term was defined and used in NMSA Section 30-9-11(A). Based on the following reasoning, the Supreme Court determined that Victim constituted a person under the unique circumstances of CSP in this case, and therefore affirmed Defendant’s convictions. View "New Mexico v. Martinez" on Justia Law

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The district court suppressed records that police officers obtained from Defendant Jaycob Price’s cell phone provider pursuant to a search warrant. Under the authority of the search warrant, the officers obtained: (1) subscriber information consisting of Defendant’s name, date of birth, social security number, and address; (2) cell-site location information (CSLI); and (3) a list of calls and text messages to and from Defendant’s cell phone. The district court ruled that the affidavit for the search warrant established probable cause to obtain Defendant’s subscriber information but failed to establish probable cause for the CSLI and call/text records, and ordered suppression of the CSLI and call/text records. The State appealed. The New Mexico Supreme Court held the district court correctly concluded that the Affidavit as a whole, together with reasonable inferences to be drawn therefrom, provided the issuing judge with a substantial basis for determining that there was probable cause to believe that Defendant’s subscriber information contained evidence of a crime. The Court held the district court erred in ruling that there was no probable cause to obtain Defendant’s CSLI and call/text records. The Court therefore affirmed in part and reversed in part the district court's order partially granting Defendant’s motion to suppress the cell phone records. The matter was remanded to the district court for further proceedings. View "New Mexico v. Price" on Justia Law

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Cases consolidated for the New Mexico Supreme Court's review shared a common issue and an opportunity to define “uniformed law enforcement officer” and “appropriately marked law enforcement vehicle” under NMSA 1978, Section 30-22-1.1(A) (2003), which defined the crime of aggravated fleeing from a law enforcement officer. The Court granted certiorari (1) in New Mexico v. Montano, 423 P.3d 1 (2018), to review the reasoning of Montano and consider whether the law enforcement officer was “uniformed” under Section 30-22-1.1(A); and (2) in New Mexico v. Martinez, A-1-CA-35111, mem. op. (May 14, 2018) (nonprecedential), to review the Montano reasoning and consider whether the law enforcement officers in Martinez and Montano were each in an “appropriately marked law enforcement vehicle” under Section 30-22-1.1(A). The Court affirmed the Court of Appeals' determination of what constituted a “uniformed law enforcement officer” and rejected its determination of what constituted an “appropriately marked law enforcement vehicle.” Therefore, the Court concluded the officer in Montano was not a “uniformed law enforcement officer” and that neither the officer in Montano nor the officer in Martinez was in an “appropriately marked law enforcement vehicle.” View "New Mexico v. Montano" on Justia Law

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Officers from the Albuquerque Police Department (APD) approached Defendant Ronald Widmer in a Walgreens parking lot in the late evening. Defendant, accompanied by a woman, was trying to start a motor scooter. APD had received an anonymous tip concerning two persons and a scooter with an ignition that “appeared to be tampered with.” The officers suspected that the scooter was stolen. After briefly speaking with Defendant and the woman, officers ran Defendant’s personal identification information and the scooter’s vehicle identification number (VIN) through the National Crime Information Center (NCIC) to check for outstanding warrants and any stolen vehicle reports. NCIC did not return a stolen vehicle report but did report Defendant’s outstanding felony warrants for trafficking drugs. Officers placed Defendant in handcuffs while they awaited confirmation that the warrants were valid. While Defendant was in custody, but before he was advised of his Miranda rights, an officer asked him, “Is there anything on your person that I should know about?” Defendant responded, “I have meth.” Officers collected a white powder from inside a pill container hanging from Defendant’s belt loop and placed it in a plastic evidence bag. After officers recovered the physical evidence, Defendant muttered, “Well, I’m gonna have another charge now.” The white powder recovered from Defendant’s belt loop tested positive for methamphetamine. As a result, Defendant was charged with felony possession of a controlled substance. At issue before the New Mexico Supreme Court was whether the officer's question to Defendant was sufficiently related to protecting officer safety to qualify for the public safety exception to the admissibility requirements of Miranda, announced in New York v. Quarles, 467 U.S. 649 (1984). The Court of Appeals determined that the question in this case did not qualify for the Quarles public safety exception, reversed Defendant's conviction for possession of methamphetamine, and remanded for a new trial. The Supreme Court disagreed, finding the Quarles public safety exception applied in this case because of the need to determine whether Defendant was armed or carrying potentially harmful drug paraphernalia before officers performed a pat-down search. The Court of Appeals was reversed and the matter remanded for further proceedings. View "New Mexico v. Widmer" on Justia Law

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After retrial, defendant Matthew Sloan appealed his convictions for burglary and felony murder. At the second trial, the State presented evidence that defendant, armed with a rifle and accompanied by two other men, broke into the victim’s house to retrieve drugs or money from the victim and that defendant shot and killed the victim during the burglary. On appeal, defendant argued: (1) the district court denied him his right to be present and to confront witnesses against him by failing to determine whether he made a valid waiver of his right to be present at three pretrial hearings; (2) he received ineffective assistance from his trial counsel; and (3) the district court committed reversible error by declining to instruct the jury on voluntary manslaughter as a lesser included offense. Finding no reversible error, the New Mexico Supreme Court affirmed defendant's convictions. View "New Mexico v. Sloan" on Justia Law

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The two issues presented by this case came to the New Mexico Supreme Court from a district court’s decision to grant Defendant Jesse Lente’s habeas petition. The first concerned Lente’s indictment, charging him with perpetrating various forms of sexual abuse on a regular basis against M.C., his stepdaughter (a so-called "resident child molester" case). The district court, relying on Valentine v. Konteh, 395 F.3d 626 (6th Cir. 2005), and New Mexico v. Dominguez, 178 P.3d 834, concluded that Lente’s indictment included “carbon copy” charges - charges that were truly identical, and not distinguishable by time or date or by specification that each charge was predicated on different acts - that impermissibly subjected him to double jeopardy. The second issue concerned the district court’s determination that M.C.’s testimony was too generic and insufficient to support Lente’s multiple convictions. Her testimony, the district court concluded, could support only one conviction for each type of sex-abuse crime Lente perpetrated and, therefore, Lente’s multiple convictions violated double jeopardy. The Supreme Court disagreed as to both issues, finding the district court wrongly interpreted the principles articulated in Valentine and Dominguez and erred in determining that Lente’s indictment included carbon copy charges that produced a double jeopardy violation. The Court took the opportunity of this case to clarify the principles courts must utilize when evaluating the sufficiency of the evidence presented in resident child molester cases. View "New Mexico v. Lente" on Justia Law

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The New Mexico Supreme Court addressed the enforceability of a guilty plea, particularly because the plea did not expressly, affirmatively state on the record, the accused plead guilty. The Court of Appeals concluded that, where the words, "I plead guilty," are not spoken, the plea is not enforceable no matter the circumstances of the plea proceeding, the overall context of the plea colloquy, or the clarity with which a defendant otherwise manifested an intent to plead guilty. The Supreme Court found this was incorrect. "Whether a plea is knowing and voluntary must be assessed from the totality of the circumstances. No magic words are either required or adequate to resolve that inquiry." View "New Mexico v. Yancey" on Justia Law

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Defendant Lloyd Aguilar was tried on an indictment charging a number of offenses related to a carjacking in which the victim was beaten and shot to death. Several of the charged offenses had complex alternative theories of culpability, which likely resulted in the jury's confusion at issue in this case. After deliberation, the jury submitted executed verdict forms to the presiding trial judge. Noticing an apparent conflict in the verdicts, the trial judge, without the knowledge or participation of the parties, returned the forms to the jurors and directed them to read the instructions again and clarify their verdicts. The jury subsequently returned revised verdict forms, which the trial judge accepted in open court with the participation of the parties before the jury was discharged. On the following day, the trial judge notified the parties of his previously undisclosed ex parte contact with the jury. After a post-trial hearing on this issue, the trial court ordered a new trial on all charges on which the jury had returned final verdicts of guilty. Both the State and Defendant appealed the trial court’s order. The State argued the trial court’s grant of a new trial was made in error, and Defendant argued that while the grant of a new trial was appropriate, the principles of double jeopardy barred retrial on the counts of murder and armed robbery. The New Mexico Supreme Court held: (1) the trial court’s new trial order was not an abuse of discretion; and (2) retrial of the counts on which the jury ultimately returned guilty verdicts would not constitute double jeopardy. View "New Mexico v. Aguilar" on Justia Law

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The State charged Defendant Manuel Baca with an open count of murder by criminal complaint. The district court found by clear and convincing evidence that Defendant committed first-degree murder and determined that he was dangerous, but not competent to stand trial. The district court ordered Defendant detained by the New Mexico Department of Health (Department) pursuant to NMSA 1978, Section 31-9- 1.5(D) (1999). Defendant appealed that order, contesting the sufficiency of the evidence. Although Defendant had not been convicted of first-degree murder, Defendant still faced a lifetime detention. The New Mexico Supreme Court determined sufficient evidence supported Defendant's criminal commitment for life, thus affirming the district court's order. View "New Mexico v. Baca" on Justia Law