Justia New Mexico Supreme Court Opinion Summaries

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The issue this case presented was one of first impression for the New Mexico Supreme Court: whether judicial conduct at trial could result in a bar to retrial under the double jeopardy clause of the New Mexico Constitution, and if so, whether the district court judge’s conduct in this case barred retrial. The Supreme Court held that judicial conduct could result in a bar to retrial under the New Mexico Constitution, and that the judicial conduct in this case barred Defendant’s retrial for felony aggravated battery against a household member with great bodily harm, misdemeanor aggravated battery against a household member without great bodily harm, and unlawful taking of a motor vehicle. View "New Mexico v. Hildreth" on Justia Law

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The issue presented in this appeal for the New Mexico Supreme Court's review centered on whether contested proceedings were not susceptible to summary judgment in the face of disputed issues of material fact. The Supreme Court found the New Mexico Public Regulation Commission (the Commission) ignored this blackletter principle when it summarily dismissed the complaint brought by Resolute Wind 1, LLC (Resolute Wind). The Commission’s summary dismissal violated the procedural due process rights of Resolute Wind and was at a minimum arbitrary, capricious, or an abuse of discretion. The Commission also erred in relying on a federal agency’s determination in an earlier, unrelated matter to dismiss the complaint. "The Commission’s procedural and substantive missteps, whether considered separately or together, require us to annul and vacate the final order appealed from and remand the matter to the Commission for further proceedings so as to afford all parties an opportunity to present evidence in support of their respective positions." View "Resolute Wind 1, LLC v. N.M. Pub. Regul. Comm'n" on Justia Law

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The issue this case presented for the New Mexico Supreme Court's review was whether the arrest of of Defendant Somer Wright by a noncommissioned, volunteer reserve deputy in violation of NMSA 1978, section 66-8- 124(A) (2007) was constitutionally unreasonable and therefore in violation of Article II, Section 10 of the New Mexico Constitution. Disagreeing with the opinion of a divided Court of Appeals panel holding that there was no constitutional violation, the Supreme Court reversed: the failure to observe the requirements of Section 66-8-124(A) resulted in an illegal arrest of Defendant and violated Article II, Section 10 of the New Mexico Constitution. Suppression of all evidence obtained as a result of the arrest was therefore required. In reversing the Court of Appeals the Supreme Court reiterated that reviewing courts were to give sufficient deference to the findings of fact of trial courts and not reweigh evidence on appeal. View "New Mexico v. Wright" on Justia Law

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Citizens for Fair Rates and the Environment and New Energy Economy, Inc., two organizations that represented energy consumers (collectively, "New Energy"), intervened in the administrative proceedings before the New Mexico Public Regulation Commission. New Energy raised several issues for the New Mexico Supreme Court's review, most of which attacked the Energy Transition Act ("ETA") on constitutional grounds. In addition to these constitutional challenges, New Energy also raised a single claim of error in the findings of the Commission relating to the requirement that Public Service Company of New Mexico’s ("PNM") submit a “memorandum . . . from a securities firm” in support of its application for a financing order. The Supreme Court declined to reach two of New Energy’s issues because they were not properly before the Court and were not essential to the disposition of this appeal. The Court further declined to address New Energy’s arguments regarding an invasion of judicial powers under Section 62-18-8(B) and Section 62-18- 22. With respect to the issues it deemed properly presented, the Court rejected New Energy’s constitutional challenges to the ETA, and concluded the Commission’s final order was based on a reasonable construction of Section 62-18- 4(B)(5) and was supported by substantial evidence. View "Citizens for Fair Rates et al. v. NMPRC" on Justia Law

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Defendant Charles Smith was convicted of battery against a household member. He appealed his conviction, arguing to both the district and Court of Appeals that, based on the evidence presented at trial, the metropolitan court erred by refusing to instruct the jury that the State had to prove that his conduct was unlawful. The Court of Appeals reversed the district court and concluded “that the court’s refusal to instruct on the essential element of unlawfulness was reversible error.” The State petitioned the New Mexico Supreme Court for a writ of certiorari and argued that an instruction on the statutory element of unlawfulness was not required because Defendant did not establish all the elements of a specific, recognized, legal defense. The Supreme Court found, however, that the State’s argument was contrary to New Mexico v. Osborne, 808 P.2d 624, which held that a defendant was not required to establish all the elements of “an exception or defense” when the term unlawful is used in a criminal statute. "Instead, when there is evidence that supports a defendant’s theory that the conduct is justifiable or excusable, a trial court has a duty to instruct the jury that the state must prove a defendant’s conduct was unlawful beyond a reasonable doubt." Although the Supreme Court's reasoning differed from the Court of Appeals, judgment was affirmed. View "New Mexico v. Smith" on Justia Law

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The parties’ pleadings centered on a single issue: the constitutionality of a June 9, 2020, directive promulgated by the New Mexico Legislative Council (the Council). The directive, among other things, banned in-person attendance at a then-impending special legislative session that was called to address COVID-19-related and other issues. Petitioners invoked Article IV, Section 12 of the New Mexico Constitution and general notions of due process as prohibiting the “closing” of the special session, and argued the Council’s directive exceeded constitutional limits. Having denied the petition in a prior order issued after oral argument, the New Mexico Supreme Court wrote to explain the reasoning and rationale for its ruling. View "Pirtle v. Legis. Council" on Justia Law

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The issue presented for the New Mexico Supreme Court's review centered on whether the State’s public health orders (PHOs) could support a claim for just compensation under either Article II, Section 20 of the New Mexico Constitution or Section 12-10A-15 of the Public Health Emergency Response Act (PHERA) (2003, as amended through 2015). With respect to the constitutional question, the Court held that the PHOs could not support a claim for a regulatory taking requiring compensation. With respect to the statutory question, it Court held the PHOs’ restrictions on business operations regarding occupancy limits and closures could not support a claim for just compensation. Furthermore, claimants for just compensation under the PHERA had to exhaust the administrative remedies set forth in Section 12-10A-15(B), (C) before seeking judicial relief. View "New Mexico v. Wilson" on Justia Law

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Twenty-seven New Mexico county clerks sought an emergency writ to compel Respondent, Secretary of State Maggie Toulouse Oliver, to mail absentee ballots directly to all registered voters in lieu of conducting in-person voting in the June 2020 primary election. They requested this extraordinary relief because the primary election was scheduled amidst a global pandemic and national and statewide public health emergency: COVID-19, a novel, potentially fatal, viral disease that was spreading unchecked throughout the population. Petitioners alleged that in-person voting could not be conducted safely under those circumstances, and they urged the New Mexico Supreme Court to hold that the requested relief was necessary to protect the health of election workers, voters, and the general public. Respondent stipulated to the petition. The Supreme Court concluded the Election Code did not permit the Secretary of State to mail absentee ballots directly to voters without a prior request from the voter. However, the Election Code permitted the Secretary to mail absentee ballot applications to voters to encourage and facilitate absentee voting. Furthermore, the Court concluded that, under the circumstances created by the COVID-19 pandemic, including the "clear and present risk to public health presented by mass gatherings and the executive orders mandating that all branches of government take all lawful steps to mitigate that risk," the Secretary of State had a duty to exercise her power to the fullest extent of the law to promote the safety of election workers and voters while conducting the June 2020 primary election. Therefore, the Supreme Court issued a writ of mandamus ordering the Secretary of State to mail absentee ballot applications to eligible voters to encourage absentee voting and minimize the health risk to the public. This remedy "promotes the public health goals mandated by the Governor while not infringing on the Legislature’s plenary power to establish election procedures." The Court issued this opinion to explain its reasoning. View "New Mexico ex rel. Riddle v. Toulouse Oliver" on Justia Law

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Defendant Sean Vest was convicted of aggravated fleeing a law enforcement officer after he led an officer on a high-speed chase through rain-slicked streets during the early morning hours. Defendant’s case regarding a police chase required the New Mexico Supreme Court to interpret the aggravated fleeing statute, NMSA 1978, § 30-22-1.1 (2003). The question presented was whether the statute’s requirement that a defendant drive “in a manner that endangers the life of another” meant that another person was literally put in danger by Defendant’s conduct (actual endangerment) or whether dangerous driving that places a community at risk of harm was enough. The Court concluded that dangerous driving that posed a risk of endangerment was enough. View "New Mexico v. Vest" on Justia Law

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Defendant Davon Lymon shot Albuquerque Police Department (APD) Officer Daniel Webster six times during a traffic stop in 2015. Defendant was charged with, and convicted of: first-degree murder, two counts of tampering with evidence related to first-degree murder, forgery, shooting from a vehicle resulting in great bodily harm, receiving or transferring a stolen vehicle, and resisting, evading, or obstructing an officer. The trial court later vacated his convictions for shooting from a vehicle and one of the two tampering counts. On direct appeal, Defendant challenged the district court’s final verdict, claiming jury coercion, improper denial of a self-defense instruction, improper admission and improper exclusion of evidence, and juror misconduct. Defendant also argued these issues resulted in a cumulative error. The New Mexico Supreme Court found defendant’s arguments were not persuasive, and affirmed Defendant’s convictions. View "New Mexico v. Lymon" on Justia Law