New Mexico Supreme Court

The New Mexico Supreme Court held that Sergeant Railey had reasonable suspicion to seize James Morgan based on dispatch information, the observed loud altercation, the apparent restraint of Morgan, and Morgan's flight.

The Court held that Defendant preserved his challenge to Juror 6, whose voir dire statements collectively demonstrated actual bias favoring law enforcement and undermined the presumption of innocence.

The Court upheld the Commission’s procedures and permanent removal of the magistrate judge. It held that the Commission had broad discretion to conduct the disciplinary hearing itself rather than appoint masters, and that combining investigative and adjudicative functions does not violate due process absent…

The Court held that the first three speedy-trial factors weighed heavily against the State: the delay exceeded three years, the State's prolonged inaction constituted bureaucratic indifference, and Defendant repeatedly asserted his right.

The New Mexico Supreme Court affirmed suppression of firearm evidence obtained during a warrantless automobile search in Texas. It held that Article II, Section 10 of the New Mexico Constitution governs the admissibility in New Mexico courts of evidence obtained by out-of-state officers in violation of that provision…

The Court held that Defendant’s five-year delay before trial did not violate his speedy-trial rights because the delay was largely attributable to Defendant or neutral, he did not meaningfully assert the right, and he showed no particularized prejudice.

The New Mexico Supreme Court affirmed the defendant’s conviction for breaking and entering. It held that placing his fingers behind a window screen constituted an entry into the dwelling under NMSA 1978 §30‑14‑8(A).

The New Mexico Supreme Court affirmed Defendant Dorall Smith’s convictions for first-degree murder and criminal damage to property, holding that the evidence of deliberate intent was sufficient, the trial court did not abuse its discretion on DNA evidence disclosure, expert communication, autopsy photographs, bad‑acts…

The Court affirmed Montoya’s conviction for intentional child abuse resulting in the death of a child under twelve, holding that the jury instructions, expert testimony, and evidence were legally sufficient.

The court reversed Daniel Consaul's child-abuse conviction and ordered dismissal with prejudice. It held that the district court should have given separate instructions because the State presented inconsistent theories of negligent/reckless conduct and intentional suffocation, and it further held that the evidence was…

The New Mexico Supreme Court reversed the Court of Appeals and affirmed the district court, holding that Gregg Crocco failed to make a prima facie showing of ineffective assistance of counsel on direct appeal because the trial record contained no evidence that he had a legitimate expectation of privacy in the house…

The Court held that Elane Photography, a public accommodation, violated the New Mexico Human Rights Act by refusing to photograph a same-sex commitment ceremony because of the customer’s sexual orientation.

The Court vacated the felony-murder conviction because the jury instruction omitted the essential element that the defendant did not act under legally sufficient provocation, which was fundamental error.

The New Mexico Supreme Court reversed the Court of Appeals' reinstatement of criminal charges that the district court had dismissed on speedy trial grounds. Applying Barker v. Wingo, the court held that a district court justly may dismiss charges when the cause of delay weighs heavily against the State because of its…

The New Mexico Supreme Court held that, although the dispute over the requested driver's-license records was arguably moot, it would decide the scope of executive privilege under the Inspection of Public Records Act (IPRA) because the issue presents a substantial public interest.

The court held that several of Swick’s convictions violated double jeopardy because the aggravated batteries were subsumed within the attempted murders and the aggravated burglary convictions arose from a single unauthorized entry.

The Court affirmed Defendant's convictions for deliberate first-degree murder and tampering with evidence. It held that the victim's statements identifying Defendant as the shooter were nontestimonial because they were made during an ongoing emergency and were elicited primarily to enable police and emergency…

The Court affirmed the first-degree murder conviction, holding that Defendant was not entitled to a self-defense instruction and that the district court properly excluded untimely or minimally relevant defense evidence.

The court affirmed the convictions for first-degree murder, negligent child abuse of Jasmine, and shooting at a dwelling, but reversed the convictions for negligent child abuse of Adrian and tampering with evidence for insufficient evidence.

The New Mexico Supreme Court held that a plea of guilty or no contest is a 'testimonial statement' under Crawford v. Washington, so the district court's judicial notice that two non-testifying co-defendants (the Romeros) had been convicted of conspiracy to commit second-degree murder violated Steve Tollardo's Sixth…

The New Mexico Supreme Court reversed Adriana Cabezuela’s conviction for intentional child abuse resulting in death, holding that the jury instruction misstates the statute by including a failure‑to‑act element and omitting the required age‑under‑twelve element.

The court affirmed the denial of Leyva's motion to suppress. It held that unrelated questioning during a traffic stop does not violate the Fourth Amendment if it causes no measurable extension of the detention, but retained a more protective, case-specific rule under the New Mexico Constitution requiring questions to…

The court affirmed the convictions for felony murder, felon in possession of a firearm, and tampering with evidence, concluding that sufficient evidence supported the verdicts, the mid-trial request for self-representation was properly denied, the failure to sever the firearm charge caused no actual prejudice, the…

The New Mexico Supreme Court held that the Court of Appeals applied the correct state summary-judgment standard but incorrectly applied federal substantive antitrust law. In an oligopoly, parallel wholesale price increases are ambiguous and cannot alone support an inference of a price-fixing agreement; plaintiffs…

The New Mexico Supreme Court held that the later felony-murder decision announced a new procedural rule because it replaced the prior fact-specific unitary-conduct analysis with a categorical bar on separate convictions for felony murder and the predicate felony.

The court affirmed Joseph Flores's first-degree murder conviction and life sentence, holding that substantial circumstantial evidence supported both his identity as the killer and the jury's finding of deliberate intent.

The court reversed the Court of Appeals and affirmed the defendant's convictions, holding that the prosecutor's closing remark about evidence of a date-rape drug was not error when read in context.

The Court held that a delay deemed presumptively prejudicial merely triggers analysis of the four speedy-trial factors and does not itself establish a constitutional violation. Applying that approach, the Court concluded that Garza’s approximately ten-month delay, slight negligent delay, limited assertion of the…

The court held that the evidence did not establish that the filthy conditions in Defendant's home created a substantial and foreseeable risk of serious harm to his two sons. It also held that the evidence did not sufficiently establish that placing his infant daughter face-down in a small drawer with soft bedding…

The court held that the Workers’ Compensation Judge improperly excluded testimony and related records from the worker’s treating health care providers merely because some treatment occurred before the providers were formally designated as authorized providers.

The court held that World Finance's arbitration provisions were substantively unconscionable because they required borrowers to arbitrate all disputes while allowing World Finance to pursue its likely remedies in court.

The court held that the defendant’s traffic stop was supported by reasonable suspicion because the officer reasonably believed the defendant violated the turn-signal statute. The statute requires signaling when there is a reasonable possibility that other traffic may be affected, and the officer’s vehicle qualified as…

The New Mexico Supreme Court held that the Oil Conservation Commission and the Oil Conservation Division exceeded their statutory authority under the Oil and Gas Act by adopting Rule 1227, which authorized them to assess civil penalties administratively for violations of the Act or related rules, orders, and…

The New Mexico Supreme Court vacated Defendant's conviction for homicide by vehicle, holding that the trial court abused its discretion in admitting the State's expert testimony on retrograde extrapolation of blood alcohol content.

The New Mexico Supreme Court reversed the Court of Appeals, which had overturned Defendant's conviction for criminal sexual penetration of a minor, and held that the trial court did not abuse its discretion in admitting (1) evidence of Defendant's uncharged acts in Colorado under Rule 11-404(B) to show intent and…

The court held that the charges involving two victims were properly joined but should have been severed because the evidence would not have been cross-admissible in separate trials under the rules governing other-acts evidence.

The Court affirmed the convictions, holding that Defendant's attempted armed robbery of Romero was distinct from the completed felony murder of Giron and that separate attempted robbery convictions were permissible because separate acts of force were used against two victims.

The court affirmed Defendant’s first-degree murder conviction because the victim’s multiple stab wounds, prolonged struggle, attempted escape, and Defendant’s statements supported a finding of deliberate intent.

The court held that the prosecutor improperly commented on the defendant's protected pre-arrest and post-Miranda silence, but the unpreserved comments did not constitute fundamental error because their prejudicial effect was minimal and the evidence was overwhelming.

The court held that the evidence was sufficient to support Garcia's conviction for being a felon in possession because the ammunition clip matching the gun, combined with the gun's location and other incriminating circumstances, supported inferences of knowledge and control.