Justia Constitutional Law Opinion Summaries

Articles Posted in New Mexico Supreme Court
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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 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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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

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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

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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