Justia New Mexico Supreme Court Opinion Summaries

A licensed horse trainer was involved in a dispute with a state racing steward after the steward refused to reinstate an assistant trainer’s license. Following a heated phone conversation in which the trainer criticized the steward, the state agency regulating horse racing initiated a disciplinary action against the trainer, alleging conduct that could negatively reflect on the integrity of horse racing. A panel of stewards found a violation and issued a conditional fine. The trainer appealed for a de novo administrative hearing but later withdrew the appeal and instead filed a lawsuit in district court, claiming the agency’s actions were a retaliatory violation of his state constitutional rights under the New Mexico Civil Rights Act.The district court denied the agency’s motion for summary judgment, holding that judicial immunity was not available to the public body under the Civil Rights Act. On interlocutory appeal, the New Mexico Court of Appeals reversed, finding that the statutory language preserved judicial immunity as a defense and that the agency was entitled to quasi-judicial immunity based on its role and the nature of the proceedings, directing entry of summary judgment for the agency.The Supreme Court of the State of New Mexico reviewed whether judicial immunity is a defense available to a public body sued under the New Mexico Civil Rights Act. The Court held that judicial immunity does apply to public bodies in this context, reasoning that the doctrine’s policy goals—protecting independent decision-making and the integrity of judicial or quasi-judicial processes—apply to both individuals and government entities. However, the Court found the record insufficient to decide whether the agency’s conduct warranted immunity under this standard and remanded the matter to the district court for further proceedings consistent with its clarified framework. The Court affirmed in part and reversed in part the Court of Appeals’ decision. View "Bolen v. N.M. Racing Commission" on Justia Law

A law enforcement officer applied for a search warrant based on information provided by a confidential informant, who had a record of reliability and admitted past drug use. The informant reported seeing a quantity of methamphetamine consistent with trafficking at the defendant’s residence within the previous seventy-two hours and stated the defendant kept a continuous supply of narcotics at her home and on her person. The affidavit described the informant’s familiarity with methamphetamine and recounted the informant’s prior accurate tips and participation in controlled drug buys. Based on this affidavit, a magistrate judge issued a search warrant. Officers executing the warrant found methamphetamine and paraphernalia, leading to the defendant's arrest and indictment for possession of methamphetamine and drug paraphernalia.The defendant moved to suppress the evidence in the Twelfth Judicial District Court, alleging that the affidavit failed to show an adequate basis for the informant’s knowledge because it lacked details on quantity, packaging, or observed sales. The district court agreed, referencing a nonprecedential Court of Appeals memorandum opinion, State v. Belknap, and found the affidavit insufficient. The State appealed. The New Mexico Court of Appeals reversed, concluding that the informant’s first-hand observation and demonstrated knowledge of methamphetamine established a sufficient basis for probable cause.The Supreme Court of the State of New Mexico reviewed the case to clarify the standard for establishing probable cause based on an informant’s tip under Article II, Section 10 of the state constitution and Rule 5-211(E) NMRA. The Court held that the affidavit provided a sufficient factual basis for probable cause because the confidential informant’s first-hand observations, combined with demonstrated credibility and knowledge, met the “basis of knowledge” prong. The Supreme Court affirmed the Court of Appeals’ decision to reverse the district court’s grant of the motion to suppress. View "State v. Perea" on Justia Law

The defendant was indicted in the district court on several felony and misdemeanor charges related to a civilian car chase involving gunfire. After indictment and entry of a scheduling order in district court, a police officer obtained two search warrants from the Bernalillo County Metropolitan Court to collect an oral swab and fingerprints from the defendant. Both supporting affidavits failed to disclose the defendant’s indictment and ongoing district court proceedings, and the second warrant was sought while the first was subject to a pending motion to quash in district court.The district court (Second Judicial District Court, Bernalillo County) quashed both warrants and suppressed the evidence, determining that the metro court lacked jurisdiction post-indictment and that the State’s actions violated the defendant’s due process rights. The district court further found that the affidavits were deceptive for omitting material facts about the pending proceedings and that the warrants conflicted with the court’s scheduling order. The suppression was without prejudice to the State seeking the same evidence via a district court motion. The State appealed, and the New Mexico Court of Appeals reversed, holding that the metro court retained authority to issue post-indictment warrants and that omissions in the affidavits did not invalidate the warrants.On certiorari review, the Supreme Court of the State of New Mexico held that metropolitan and magistrate courts retain concurrent authority to issue search warrants after formal criminal proceedings have begun in district court. However, the district court may quash such warrants under its inherent authority to manage its docket and proceedings. The Supreme Court found no abuse of discretion in the district court’s decision to quash the warrants and suppress the evidence, and reversed the Court of Appeals, affirming the district court’s ruling. View "State v. Chavez" on Justia Law

The case concerns an insurance dispute in which the plaintiff’s father purchased liability insurance for three vehicles from Progressive Direct Insurance Company, but rejected uninsured/underinsured motorist (UM/UIM) coverage by signing a rejection form. After the plaintiff was seriously injured in a car accident where damages exceeded the other driver’s coverage limits, he filed a claim for UIM coverage with Progressive, which was denied due to the prior rejection of coverage. The plaintiff then sued Progressive, arguing that the insurer’s offer of UM/UIM coverage was invalid because it was made on a per-policy, rather than a per-vehicle, basis.At the trial level, the District Court granted summary judgment in favor of Progressive, dismissing the plaintiff’s claims with prejudice. The New Mexico Court of Appeals affirmed the dismissal, relying on its earlier ruling in Lueras v. GEICO General Insurance Co., which found that New Mexico law did not require UM/UIM coverage to be offered on a per-vehicle basis. The Court of Appeals concluded that Progressive’s per-policy offer complied with existing law, and thus the plaintiff’s rejection of coverage was valid.The Supreme Court of the State of New Mexico reviewed the case on certiorari and held that New Mexico’s UM/UIM statute requires insurers to offer UM/UIM coverage on a per-vehicle basis and disclose premiums for each vehicle accordingly. The Court found that per-policy, all-or-nothing offers frustrate the legislative purpose of encouraging consumers to purchase UM/UIM insurance and limit consumer choice. The Court ruled that the plaintiff’s rejection of coverage was invalid because it was not knowingly and intelligently made under the required per-vehicle offer structure. The Supreme Court reversed the lower courts’ decisions and remanded for further proceedings, applying its holding with selective prospectivity. View "Kileen v. Didio" on Justia Law

The case concerns a dispute that arose after a company, Motiva Performance Engineering, failed to deliver on an agreement to upgrade a vehicle for the plaintiff, resulting in a jury verdict against Motiva for breach of contract, fraudulent misrepresentation, and violation of the Unfair Practices Act. The company’s managing member, who was also its attorney, transferred Motiva’s Ferrari to another company he controlled shortly after the verdict and subsequently used the car as collateral for a loan without disclosing this to the court. Additional questionable conduct included failing to disclose or potentially backdating a promissory note and depositing insurance proceeds into his personal account. These acts occurred while the court was overseeing asset proceedings to satisfy the judgment against Motiva.Following these actions, the district court held a hearing and issued a sanctions order against the managing member and his associated entities for what it termed remedial contempt, requiring payment of the underlying judgment and a $50,000 donation to charity. The sanctions order also referenced Rule 1-011 NMRA (Rule 11) violations due to misstatements in court filings. The managing member moved for reconsideration, arguing the evidence did not support remedial contempt, but appealed the order before the motion was decided. The New Mexico Court of Appeals affirmed the sanctions on both inherent powers and Rule 11 grounds, though a dissent questioned the breadth of conduct relied upon under Rule 11.The Supreme Court of the State of New Mexico held that the district court erred by imposing punitive contempt sanctions without affording criminal-level due process protections and that such sanctions could not be justified under the court’s inherent powers without those protections. However, the court upheld the sanctions under Rule 11, as the due process requirements for Rule 11 are not equivalent to those for contempt. The holding was limited to willful misstatements made in documents filed with the court. The court affirmed the Court of Appeals in part, reversed in part, and remanded for further proceedings. View "Butler v. Motiva Performance Engineering, LLC" on Justia Law

Attorney Alan Maestas was found guilty of direct punitive contempt for refusing to proceed to trial despite the district court’s orders and warnings. As a sanction, the district court imposed a ten-day jail sentence, suspended in full, and ordered Maestas to pay a $1,000 fine to the New Mexico State Bar Foundation. The contempt finding and sanction arose from Maestas’s conduct in the presence of the court, which the court determined warranted punitive measures.The New Mexico Court of Appeals reviewed the district court’s contempt finding and affirmed it, but found that the initial sanction imposed was an abuse of discretion. On remand, the district court imposed the revised sanction described above. Subsequently, the Court of Appeals certified to the Supreme Court of New Mexico the question of whether a contempt fine ordered payable to a third party is permitted by statute and the New Mexico Constitution.The Supreme Court of New Mexico held that a fine payable to a third party is permitted under the judiciary’s inherent and broad contempt power and is constitutional. The Court clarified that only fees collected by the judicial department, not fines merely imposed, are subject to the limitations of Article VI, Section 30 of the New Mexico Constitution. The Court distinguished between “fees” and “fines,” finding that the constitutional provision applies only to fees collected, not to punitive contempt fines directed to third parties. The Court also found no relevant legislative constraint on the type of fine imposed in this case. The matter was remanded to the Court of Appeals for consideration of other issues raised on appeal. View "State v. Maestas" on Justia Law

Two individuals, Mario Cabral and Vanessa Mora, were shot and killed in their home in March 2018. The defendant, who had a child with Cabral and was involved in a contentious custody dispute, was accused of hiring a hitman, Edward Alonso, to kill Cabral. Alonso testified that the defendant offered him money and provided details about Cabral’s residence, but he ultimately did not carry out the murder. The prosecution presented circumstantial evidence, including testimony about the defendant’s acquisition of a .45-caliber gun, photographs of Cabral’s home found on her phone, and statements suggesting her boyfriend, Flores, might commit the murder if Alonso did not. The defendant denied involvement, but the jury convicted her of first-degree murder of Cabral, conspiracy to commit first-degree murder, and criminal solicitation of first-degree murder.The case was tried in the District Court of Doña Ana County, where the defendant objected to the prosecution’s cross-examination about her six-month-old child’s positive methamphetamine test, arguing lack of notice and relevance. The district court allowed limited questioning on this topic. The jury acquitted the defendant of Mora’s murder but convicted her on the other charges.On direct appeal, the Supreme Court of the State of New Mexico reviewed the evidentiary ruling and found that the district court abused its discretion by admitting the inquiry into the child’s drug test, as it was inadmissible under the relevant evidence rules and not justified as rebuttal character evidence. The error was deemed not harmless, given its impact on the defendant’s credibility. The Supreme Court reversed all convictions and remanded for a new trial. The court also held that the convictions for conspiracy and solicitation did not violate double jeopardy and that sufficient evidence supported the murder conviction. Additionally, the court emphasized the public’s First Amendment right to access criminal trials, criticizing the district court’s prohibition of notetaking by observers. View "State v. Cardenas" on Justia Law

A deadly shooting occurred at a house party in Las Cruces, New Mexico, in July 2021. During a chaotic altercation, multiple gunshots were fired, resulting in the death of Nicodemus Gonzales and damage to a vehicle driven by Jayissa Borrunda. Eyewitnesses described seeing the defendant and his cousin brandishing guns with laser sights. Forensic evidence was inconclusive as to which weapon caused the fatal injury. The defendant, who was seventeen at the time, was charged as a Serious Youthful Offender with first-degree (willful and deliberate) murder and other related offenses.The District Court of Doña Ana County acquitted the defendant of first-degree (willful and deliberate) murder but allowed the case to proceed to the jury on first-degree felony murder, predicated on aggravated assault, as well as other charges. The jury convicted the defendant of first-degree felony murder (as an accomplice to aggravated assault), aggravated assault, two counts of conspiracy, and shooting at a motor vehicle. The court imposed a thirty-year sentence for felony murder, an enhanced sentence for aggravated assault, and additional concurrent sentences for the other convictions.The Supreme Court of the State of New Mexico reviewed the case. It held that aggravated assault is a noncollateral felony and cannot serve as the predicate for felony murder; therefore, the defendant’s felony murder conviction must be vacated as a legal nullity. The Court further held that double jeopardy does not bar retrial for felony murder or its lesser-included offenses when a conviction is reversed for a nonexistent crime, as this constitutes trial error rather than an acquittal. The Court also vacated one conspiracy conviction for lack of evidentiary support and reversed the four-year firearm enhancement as unauthorized by statute. The remaining convictions were affirmed, and the case was remanded for further proceedings consistent with the opinion. View "State v. Revels" on Justia Law

A group of New Mexico residents filed lawsuits against several out-of-state law firms, alleging that these firms conspired with tobacco companies and industry organizations to mislead the public about the dangers of cigarette smoking, resulting in personal injuries. The law firms, based in Missouri, the District of Columbia, and North Carolina, had no significant business or physical presence in New Mexico. The plaintiffs argued that the law firms’ participation in a nationwide civil conspiracy, which included acts affecting New Mexico, established grounds for the state’s courts to exercise specific personal jurisdiction over them.The First Judicial District Court denied the law firms’ motions to dismiss for lack of personal jurisdiction, relying on a New Mexico Court of Appeals decision that recognized “conspiracy jurisdiction” as a valid basis for specific personal jurisdiction. The district court found that the plaintiffs had shown the law firms participated in a conspiracy that “reached into New Mexico,” but did not make detailed factual findings. The law firms then petitioned the Supreme Court of the State of New Mexico for writs of prohibition to prevent the district court from exercising jurisdiction.The Supreme Court of the State of New Mexico held that conspiracy jurisdiction is constitutional if it is limited to situations where a defendant knowingly and actively participates in a civil conspiracy targeting the forum state, with knowledge that co-conspirators would commit acts in or aimed at that state. However, the Court found that the plaintiffs failed to make a prima facie showing that the law firms either participated in such a conspiracy or knew of acts in furtherance of the conspiracy that created minimum contacts with New Mexico. As a result, the Court directed that the law firms be dismissed from the lawsuits. View "Shook v. Wilson" on Justia Law

A woman who served as the co-leader of a religious group in rural New Mexico was charged with multiple crimes after a twelve-year-old child, E.M., died at the group’s compound. The woman exercised strict control over the group’s members and limited their access to outside medical care. E.M. became seriously ill, was denied food as punishment, and ultimately died after his condition worsened. The child’s death was not reported to authorities until two years later, when other group members alerted police. An autopsy determined the cause of death was a probable infectious disease, but the exact cause could not be identified due to decomposition.The woman was initially indicted on several charges involving two children. The charges relating to another child, M.G., were severed, and she was convicted by a jury on those counts, receiving a 72-year sentence. Shortly after, she entered a plea agreement on the E.M.-related charges, including child abuse resulting in great bodily harm, and was sentenced to 18 years to run concurrently. Later, the M.G.-related convictions were set aside due to a Brady violation, and those charges were dismissed. The woman then filed a habeas petition seeking to vacate her plea in the E.M. case, arguing actual innocence, among other grounds. The district court rejected most claims but granted relief on actual innocence, finding her conduct did not legally constitute great bodily harm.The Supreme Court of the State of New Mexico held that a defendant convicted by plea agreement may assert a freestanding claim of actual innocence, applying the same clear and convincing evidence standard as for convictions after trial. However, the Court found that the district court’s determination of actual innocence was not supported by substantial evidence, as no new affirmative evidence was presented and the district court’s own findings implicated the defendant in the crime. The Supreme Court reversed the grant of habeas relief and remanded the case. View "State v. Green" on Justia Law