Justia New Mexico Supreme Court Opinion Summaries

Defendant Christina Banghart-Portillo pleaded guilty to tampering with evidence, and conspiracy to commit tampering with evidence, contrary to (Count 1 and Count 2, respectively), each of which was a fourth-degree felony offense, under a written plea agreement. Because Defendant had a prior felony conviction, each sentence was enhanced at her initial sentencing by one year under New Mexico’s habitual offender statute. Defendant also admitted her identity in a second prior felony at the time of her sentencing, yet the district court imposed no additional enhancement at that time. The district court imposed consecutive sentences. The central issue this case presented for the New Mexico Supreme Court's review was whether Defendant had a reasonable expectation of finality for Count 1 such that the district court no longer had jurisdiction when it applied the habitual offender enhancement to that Count. Defendant argued on appeal that the district court’s enhancement of the Count 1 sentence resulted in a double jeopardy violation because the court had lost jurisdiction by the time of the enhancement. The Court of Appeals held that the district court retained jurisdiction to apply a habitual offender enhancement to Count 1. The Supreme Court concluded Defendant did not have a reasonable expectation of finality in Count 1 at the time that the district court enhanced Defendant’s sentence because the district court had previously informed her of the consequences she faced if she violated probation. Therefore, it affirmed the Court of Appeals and held that the district court properly retained jurisdiction to apply a habitual offender enhancement to Count 1. View "New Mexico v. Banghart-Portillo" on Justia Law

Eight named inmates and two nonprofit organizations (collectively, plaintiffs) filed an amended complaint in district court seeking a mixture of a classwide writ of habeas corpus and classwide injunctive and declaratory relief. Plaintiffs alleged that the State’s management of COVID-19 in New Mexico prisons violated inmates’ rights under the New Mexico Constitution. The district court dismissed the amended complaint, concluding that it lacked subject-matter jurisdiction because the individual inmate-plaintiffs failed to exhaust the internal grievance procedures of the New Mexico Corrections Department (NMCD) before seeking relief, as required by NMSA 1978, Section 33-2-11(B) (1990). Agreeing with the result, but not all of its reasoning, the New Mexico Supreme Court affirmed the district court: "to satisfy the habeas corpus exhaustion requirement under Rule 5-802(C) for an entire plaintiff class, one or more named class members must exhaust administrative remedies for each claim. Because no Named Plaintiff exhausted or sought to exhaust NMCD’s internal grievance procedures, we affirm." View "Anderson, et al. v. New Mexico" on Justia Law

On interlocutory appeal, the State challenged the Court of Appeals’ affirmance of the district court’s pretrial ruling that almost all statements made by Declarant Kimbro Talk to sexual assault nurse examiner (SANE) nurse Gail Starr were inadmissible as violating Defendant Oliver Tsosie’s confrontation rights under the Sixth Amendment. The district court concluded that Declarant’s statements sought by the State for use at Defendant’s trial were testimonial in nature, and thus inadmissible, pursuant to Crawford v. Washington, 541 U.S. 36 (2004) and Davis v. Washington, 547 U.S. 813 (2006). The New Mexico Supreme Court reversed and, without ruling on other considerations of admissibility, held that almost all of the excluded statements were nontestimonial in nature and thus did not violate Defendant’s rights under the Confrontation Clause. View "New Mexico v. Tsosie" on Justia Law

Child, then age seventeen, became Facebook friends with a former schoolmate, Jeremiah Erickson (Erickson), then age nineteen. The two conversed primarily through their respective Facebook Messenger accounts. Child and Erickson used Messenger to arrange in-person meetings, during which Erickson drove to Child’s house to pick her up and drive her somewhere to “hang out.” It was the second of these meetings that gave rise to the events leading to Child’s adjudication. Both Erickson and Child testified that their get-together on the night of February 24, 2020, did not end well, and each provided a different narrative as to what unfolded. At Child’s adjudication, the State sought to introduce evidence of communications between Child and Erickson the State alleged took place on Facebook Messenger the day after an incident involving Erickson’s vehicle. The State sought to authenticate the messages through Erickson’s testimony as to his personal knowledge of both the accuracy of screenshots and his history of Facebook Messenger communications with Child, as well as through the contents of the messages themselves. Child’s counsel objected to the authentication of the exhibits, arguing the screenshots did not show with certainty the messages were sent from Child’s Facebook account and emphasizing what counsel characterized as the inherent difficulty in “lay[ing a] foundation on Facebook Messenger messages because anybody can have access to somebody’s phone or Facebook account.” The district court overruled the objection, and the evidence was admitted. Child was subsequently adjudicated delinquent and appealed the district court’s judgment and disposition. The New Mexico Supreme Court agreed with the Court of Appeals that the traditional authentication standard set out in Rule 11-901 provided the appropriate legal framework for authenticating social media evidence. But the Court disagreed with appellate court's conclusion that the State failed to meet the threshold for authentication established under that rule, much less that the district court abused its discretion in finding the State had met its burden. The Supreme Court held the State’s authentication showing was sufficient under Rule 11-901 to support a finding that, more likely than not, the Facebook Messenger account used to send the messages belonged to Child and that Child was the author of the messages. Accordingly, the Court of Appeals was reversed and Child’s delinquency adjudications were reinstated. View "New Mexico v. Jesenya O." on Justia Law

Defendant-respondent Jesse Mascareno-Haidle was charged committing a series of burglaries of residential homes in Albuquerque. The State filed a motion for pretrial detention, and to support its motion, the State presented the investigating detective's criminal complaint-arrest warrant affidavit, the pretrial services public safety assessment (PSA) recommending that Defendant be released on his own recognizance, the results of a criminal history search pertaining to Defendant, and the register of actions in the case. At the hearing for the motion, "noticeably lacking" was any testimony from the detective and any argument that no conditions of release could protect the community from Defendant if he were released. The district court judge denied detention. The district court judge found “that the magnitude of the allegations are inherently dangerous” but “that the State has failed to prove by clear and convincing evidence that no release conditions will reasonably protect the safety of another person or the community.” The State filed a second motion for pretrial detention. As with the first motion, the State supported its second motion with the detective's second criminal complaint-arrest warrant affidavit, an updated pretrial services PSA that again recommended Defendant’s release on his own recognizance, the results of a criminal history search, and the register of actions in the case. An arrest warrant was issued, and Defendant was arrested at his home - his required location under the existing conditions of his release. At the conclusion of a second hearing on the State's motion, the district court again denied the motion. The New Mexico Supreme Court concurred with the district court that the State failed to meet its evidentiary burden to place defendant in pretrial detention, and affirmed the appellate court's affirmance of the district court. View "New Mexico v. Mascareno-Haidle" on Justia Law

A jury awarded four Plaintiffs a total of more than $165 million in damages to compensate them for a tragic accident that claimed half of a young family in a single instant, and left surviving family members physically and emotionally injured. Defendants appealed the verdict as excessive, contending it was not supported by substantial evidence and was tainted by passion or prejudice. The Court of Appeals affirmed the verdict. The New Mexico Supreme Court granted certiorari to consider whether the Court of Appeals erred by: (1) applying an abuse of discretion standard to review the district court’s denial of Defendants’ motion for a new trial because the ruling was made by a successor judge who did not oversee the trial; and (2) affirming the district court’s denial of Defendants’ motion for a new trial on grounds that the verdict was excessive. The Supreme Court held: (1) because it reviews claims of excessive verdicts de novo, it did not need to adopt a new standard of review for decisions of successor judges assigned under the circumstances of this case, as requested by Defendants, and the Court declined to do so; and (2) under current law, substantial evidence supported the verdict and the record did not reflect that the verdict was tainted by passion or prejudice. The Court therefore affirmed the Court of Appeals. View "Morga v. FedEx Ground Package Sys., Inc." on Justia Law

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

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

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

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