Justia Criminal Law Opinion Summaries

Defendant Christopher Sisneros was convicted in 2011 of first-degree murder, felony murder, shooting from a motor vehicle resulting in great bodily harm, and aggravated fleeing from a law enforcement officer. Sentenced to life imprisonment plus sixteen and one-half years, Defendant appealed his conviction directly to the Supreme Court. After finding that defendant was subject to Double Jeopardy, the Supreme Court remanded the case to the district court to vacate his convictions for felony murder and shooting from a motor vehicle and re-sentencing. View "New Mexico v. Sisneros" on Justia Law

In 2008, Defendant Andrew Miller faced sixty-one counts consisting mostly of fraud and embezzlement charges between two indictments against him. He entered into a plea agreement with the State covering both indictments, which the district court accepted. Defendant pleaded Guilty or No Contest to four second-degree felonies and two third-degree felonies. In exchange for Defendant's pleas, the State dropped all but six charges against him. The Supreme Court issued a writ of certiorari to review the Court of Appeals' decision that the district court's sentence of Defendant Andrew Miller violated the terms of a plea agreement that the district court had accepted. Upon review, the Supreme Court agreed with the Court of Appeals that defendant's sentence violated the plea agreement. However, the high court disagreed with the remedy that the Court of Appeals ordered and clarify case law on this account. Accordingly, the Court reversed the Court of Appeals and remanded the case to the district court for further proceedings. View "New Mexico v. Miller" on Justia Law

Defendant Aquilino Lopez was stopped for speeding and arrested for driving with a suspended license. While performing a search incident to arrest, the arresting officer discovered a clear bag containing a green leafy substance suspected to be marijuana. During an inventory of the contents of Defendant’s car, officers discovered another bag containing a white powdery substance they believed to be cocaine. Defendant was charged with possession of a controlled substance with intent to distribute, possession of marijuana, and driving with a suspended or revoked license. Defendant entered a special appearance in the district court and filed a motion to dismiss or, in the alternative, to remand the case to the magistrate court for another preliminary examination. The motion alleged that the magistrate had violated Defendant’s confrontation rights under both the Sixth Amendment to the United States Constitution and Article II, Section 14 of the New Mexico Constitution by admitting the forensic laboratory report into evidence at the preliminary hearing without an opportunity for the defense to personally cross-examine the laboratory analyst who prepared the report. The motion argued that as a result the district court did not have jurisdiction to proceed further in the case. After a hearing, the district court denied Defendant’s motion. Defendant subsequently entered a conditional guilty plea. The Court of Appeals certified the appeal directly to the Supreme Court. After careful consideration, the Supreme Court concluded that the full constitutional right of confrontation in criminal prosecutions does not apply at pretrial probable cause determinations. The right of confrontation in Article II, Section 14 of the New Mexico Constitution, and the right of confrontation guaranteed by the Sixth Amendment to the United States Constitution, applies only at a criminal trial where guilt or innocence is determined. The Court overruled the contrary precedent of "Mascarenas v. New Mexico," (458 P.2d 789), to the extent that it held otherwise. View "New Mexico v. Lopez" on Justia Law

In this case, the district court rejected defendant Juan Pinon-Garcia's request for it to review a municipal court dismissal for an abuse of discretion. Defendant sought dismissal of the case against him because the government's key witness failed to appear for the scheduled trial. The district court also declined to independently consider defendant's motion to dismiss because the court believed it was compelled to proceed directly to a trial de novo. Because the right of appeal from courts not of record is the right to a trial or hearing de novo in district court, the Supreme Court concluded the district court must make an independent determination of the merits of the pretrial motion. "If district courts are not permitted to review a lower court’s grant or denial of potentially dispositive pretrial motions on appeal, the power of lower courts to grant relief when constitutional safeguards and procedural rules, such as speedy trial, double jeopardy, or discovery rules, are violated would be meaningless." The case was remanded to the district court for consideration of the motion to dismiss. View "City of Farmington v. Pinon-Garcia" on Justia Law

The issue before the Supreme Court in this case was whether the right to personal confrontation of adverse witnesses in criminal prosecutions applies at the pretrial probable cause determination. The Court held that it does not because the right of confrontation in Article II, Section 14 of the New Mexico Constitution, as with the right of confrontation guaranteed by the Sixth Amendment to the United States Constitution, applies only at a criminal trial where guilt or innocence is determined, and the Court overruled the contrary precedent of "Mascarenas v. New Mexico," (458 P.2d 789). View "New Mexico v. Lopez" on Justia Law

Defendant Michael Samora was convicted of first-degree murder and other crimes for the beating death of his girlfriend and a subsequent robbery and stabbing at an Albuquerque convenience store. He argued on appeal to the Supreme Court that his convictions should have been reversed as a result of the district court’s excusal of a Spanish-speaking prospective juror who had difficulty understanding English. While the Court agreed with Defendant’s argument that the juror’s dismissal violated Article VII, Section 3 of the New Mexico Constitution, the Supreme Court held that it was an unpreserved error and not the kind of fundamental error that required reversal of a conviction without first having raised it at trial. View "New Mexico v. Samora" on Justia Law

Defendant Manuel Turrietta argued on appeal to the Supreme Court that his right to a public trial was violated when the district court partially closed the courtroom during the testimony of two confidential informants. Upon review, the Supreme Court concluded that the state did not demonstrate an overriding interest for closing the courtroom, and that the district court failed to adequately assess the possible alternatives to closure, or to make adequate findings to support its decision. A "substantial reason" standard does not meet constitutional muster, and the Court held that courts must apply a "Waller" standard prior to closure. As such, Defendant's Sixth Amendment right to a public trial was violated, and the courtroom closure was unconstitutional. Accordingly, the Court remanded the case for a new trial. View "New Mexico v. Turrietta" on Justia Law

A jury convicted Defendant Aaron Ramos of violating a protection order. He appealed, arguing that he was refused a jury instruction that would have required the jury to find that he had “knowingly” violated the protection order. The Court of Appeals upheld the district court’s decision not to give the “knowingly” instruction. The Supreme Court read the language and structure of the statute at issue and its legislative policy to conclude that it was reversible error to deny Defendant's requested instruction. The case was reversed and remanded for a new trial. View "New Mexico v. Ramos" on Justia Law

Defendant was convicted for trafficking an imitation controlled substance (here, baking soda packaged to look like cocaine). The issue on appeal to the Supreme Court had to reconcile the application of the state Imitation Controlled Substances Act (which allowed a jury to consider prior convictions related to controlled substances or fraud), and the Rules of Evidence, which restrict the use of prior bad acts (including criminal convictions). To avoid a conflict, the Court held that any evidence of prior convictions referred to by the statute must also be admissible under the rules of evidence. In this case, Defendant's prior convictions did not satisfy Rule 404(B), and therefore their admission into evidence was made in error. The Court found the admission harmless, however, and affirmed Defendant's convictions. The case was remanded to correct a sentencing error. View "New Mexico v. Serna" on Justia Law

Defendant Orlando Torrez was convicted of felony murder after a jury rejected his claim of self-defense. Defendant raised several issues on appeal: (1) whether there were double jeopardy violations; (2) whether the trial court erred in its jury instructions; (3) the alleged denial of process when a witness failed to appear; and (4) the insufficiency of the evidence to support his conviction. Finding none of Defendant's claims of error persuasive, the Supreme Court affirmed his conviction. View "New Mexico v. Torrez" on Justia Law