Justia New Mexico Supreme Court Opinion Summaries

Defendant Antonio Cruz was convicted at his arraignment at a New Mexico magistrate court in 2017. His conviction was obtained through an uncounseled plea of no contest to a single count of misdemeanor criminal damage to property of a household member. At arraignment, he requested an attorney. The magistrate appointed the Law Offices of the Public Defender (LOPD) to represent him. One month later, an attorney from the LOPD entered an appearance in the case and sought to withdraw the uncounseled plea. The magistrate court denied the request to withdraw the plea and proceeded to sentencing. Defendant appealed. The district court dismissed the appeal without prejudice because Defendant did not bring the case to trial within six months. Subsequently, following a show cause hearing, the district court dismissed the appeal with prejudice and remanded the case to magistrate court to enforce the sentence. The Court of Appeals upheld the district court’s dismissal of the case. The New Mexico Supreme Court granted certiorari to consider Defendant’s argument he was denied due process and received ineffective assistance of counsel. After review, the Court concluded that Defendant’s plea was void because the magistrate court deprived Defendant of the right to counsel and due process by accepting his plea of no contest without providing him counsel. Furthermore, the Court concluded the district court lacked authority to dismiss Defendant’s timely-filed appeal because there was no longer a six-month rule applicable to district courts, and it was the State, not Defendant, that bore the burden of bringing a case to trial. Accordingly, the Court of Appeals’ affirmance of Defendant’s conviction was reversed. View "New Mexico v. Cruz" on Justia Law

The issue this case presented for the New Mexico Supreme Court’s review centered on whether the cap on all damages other than medical care and punitive damages under the Medical Malpractice Act (MMA), violated the right to trial by jury guaranteed by Article II, Section 12 of the New Mexico Constitution. Plaintiff Susan Siebert successfully sued her doctor, Rebecca Okun, M.D., and Women’s Specialists of New Mexico, Ltd. (WSNM) for medical malpractice under the MMA. Following the return of the jury’s verdict, Defendants Dr. Okun and WSNM moved to reduce the jury award of $2,600,000 to conform with the $600,000 cap on all nonmedical and nonpunitive damages in MMA actions. The district court denied Defendants’ motion, concluding that the MMA nonmedical, nonpunitive damages cap infringed the state constitutional right to a trial by jury. The Supreme Court held that the MMA nonmedical, nonpunitive damages cap did not violate Article II, Section 12, and reversed the district court’s denial of Defendants’ motion to conform the judgment in accordance with the statutory cap. View "Siebert v. Okun" on Justia Law

In 2003, the decedent’s body was discovered lying on the living room floor of Defendant Ricky Quintana’s residence. The decedent had been stabbed multiple times, and his body had been subjected to mutilation, both before and after death. Defendant was charged with an open count of murder and tampering with evidence. In 2006, and again in 2014, the parties filed stipulations including that Defendant was incompetent to stand trial and remained dangerous, that clear and convincing evidence supported the charge of second-degree murder against Defendant, and that aggravating circumstances existed warranting the addition of three years to his statutory fifteen-year term of commitment. The district court based its order of commitment on findings by clear and convincing evidence from both hearings relating to two “valid aggravating factor[s].” Evidence had been presented at the hearings that Defendant had been in a state of psychosis when committing the murder charged and when previously attacking another victim in a separate incident, and that Defendant was not reliable to take his antipsychotic medications without supervision. Defendant appealed on the ground that enhancing a term of commitment based on aggravating circumstances was not permitted under the New Mexico Mental Illness and Competency Code (NMMIC). The Court of Appeals consequently affirmed the ruling of the district court that extended Defendant’s term of commitment based on aggravating circumstances. The New Mexico Supreme Court affirmed and issued this opinion to clarify that a term of commitment under Section 31-9-1.5 may be increased under Section 31-18- 15.1 due to aggravating circumstances that bear a direct relation to a defendant’s dangerousness and that are supported by clear and convincing evidence. View "New Mexico v. Quintana" on Justia Law

When Angela Russ (Spouse) and Jeffery Russ (Veteran) divorced, they agreed to divide Veteran’s military retirement pay as part of the community property. Nonetheless, about eight years after their divorce, Veteran waived his retirement pay in order to receive a disability benefit from the federal government. His waiver occurred after Mansell v. Mansell, 490 U.S. 581 (1989) was issued, but before Howell v. Howell, ___ U.S. ___, 137 S. Ct. 1400 (2017) was issued. The question presented for the New Mexico Supreme Court’s review was whether the Court of Appeals correctly determined that Howell did not apply to this case. If the Howell Court’s application of the Mansell rule applied, Veteran could unilaterally change his federal benefit as he did. This change precluded Spouse from receiving any of his retirement benefit from the federal government, regardless of what he agreed to when they divorced. If the Howell Court’s application of the Mansell rule did not apply, then Veteran had to indemnify Spouse for her share of his waived retirement benefit. “Although equitable principles may suggest that we should determine that Howell does not apply in this case, the Supremacy Clause of the federal constitution, U.S. Const. art. VI, cl. 2, precludes that application of equity.” The New Mexico Supreme Court reversed the Court of Appeals’ determination that Howell was not given full retroactive effect in New Mexico, and remanded for further proceedings. View "Russ v. Russ" on Justia Law

In 2011, defendant Robert Chavez and co-conspirators beat and shot Richard Valdez. The victim’s body was found burned in a 2006 Suzuki station wagon. After a joint trial, Defendant was convicted of first-degree murder, conspiracy to commit first-degree murder, arson, and tampering with evidence due to his involvement in the murder of Victim. Defendant appealed, arguing: (1) the trial court erred when it failed to sever the joint trial; (2) his convictions violated principles of double jeopardy; and (3) there was insufficient evidence to support his arson conviction. Finding no reversible error, the New Mexico Supreme Court affirmed Defendant’s convictions. View "New Mexico v. Chavez" on Justia Law

The issue presented for the New Mexico Supreme Court’s review centered on the executive branch’s authority to impose business restrictions during a pandemic. Specifically, the Court was asked to address: (1) whether Petitioners were authorized to restrict or close businesses when necessary for the protection of public health; and (2) whether the renewed temporary closure of indoor dining at restaurants and breweries, mandated by a July 13, 2020, emergency public health order (July Order), was arbitrary and capricious. With respect to the first question the Supreme Court held, consistent with its opinion in Grisham v. Reeb, 2020-NMSC-___, (S-1-SC-38336, Nov. 5, 2020), that Petitioners were so authorized. With respect to the second question, the Court held that the July Order’s temporary closure of indoor dining was not arbitrary and capricious. View "Lujan Grisham v. Romero" on Justia Law

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

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

As part of a project to construct a new road along the North Diversion Channel, the City of Albuquerque initiated a condemnation proceeding to acquire a thirty-foot-wide strip of land across a 9.859-acre property (Property) owned by SMP Properties, LLC, whose managing member was R. Michael Pack (collectively, SMP). The district court granted Albuquerque entry and ordered the distribution of $143,850 to SMP as “just compensation” for the condemned property. SMP asserted it did not receive full compensation because, prior to initiating the condemnation action, Albuquerque directly communicated its intent to condemn a portion of the Property to one of SMP’s tenants, SAIA Motor Freight Line, LLC (SAIA). Hearing of Albuquerque’s intent to condemn, SAIA apparently decided not to renew its lease before Albuquerque filed the contemplated condemnation action, determining that the condemnation would disrupt its operation and use of the portion of the Property it leased. Based on Albuquerque’s pre-condemnation communications with SAIA and SAIA’s subsequent failure to renew its lease, SMP asserted an inverse condemnation claim against Albuquerque seeking consequential damages, including lost rental income and devaluation of the Property adjacent to the thirty-foot wide strip that Albuquerque condemned. Albuquerque moved for partial summary judgment on SMP’s “claims for consequential damages relating to the loss of potential tenant leases.” The district court granted Albuquerque summary judgment and concluded that Albuquerque’s pre-condemnation activity did not constitute “substantial[] interfere[nce] with the landowner’s use and enjoyment of the [P]roperty,” and therefore, no taking (in the form of an inverse condemnation) occurred. The Court of Appeals reversed the district court, finding there were disputed issues of material fact to preclude summary judgment. Though it did not adopt the appellate court’s reasoning, the New Mexico Supreme Court affirmed reversal of summary judgment. View "City of Albuquerque v. SMP Props., LLC" on Justia Law

The Harding County, New Mexico Board of County Commissioners, the Mosquero Municipal Schools Board of Education, and the Roy Municipal Schools Board of Education (collectively, Petitioners) petitioned for a writ of mandamus to compel the New Mexico Taxation and Revenue Department and the department’s Secretary Stephanie Schardin Clarke (collectively, the Department) to establish values for two high-voltage transmission lines in Harding County and report those values to the Harding County Assessor (Assessor) so that property taxes could be assessed on the lines. A district court issued the writ, and a dispute arose over whether the Department complied as ordered. Petitioners moved for an order to show cause, and requested fees associated with petitioning for the writ. After full briefing and a hearing, the district court held the Department in contempt for failing to comply with the district court’s order and awarded Petitioners their costs and fees related to the order to show cause. The Department appealed and sought review of the Peremptory Writ, the contempt holding, and the award of costs and fees. The Court of Appeals declined to review the merits of the Peremptory Writ, concluding that the Department failed to timely appeal that final order. However, the Court of Appeals reviewed the “issues relating to the Contempt Order and the Order for Fees and Costs” and affirmed the district court. The Department petitioned the New Mexico Supreme Court for certiorari review pursuant to Rule 12-502 NMRA. The Court granted certiorari, and finding no reversible error, affirmed the Court of Appeals. View "Harding Cnty. Bd. of Comm'rs v. N.M. Tax'n & Revenue Dep't" on Justia Law