AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

The Defendant was involved in an incident where he allegedly assaulted a victim, Rivera, with a knife and attempted to run over Rivera and two other individuals, Herrera and Hicks, with a car. The events occurred after Rivera was coerced into driving the Defendant and a co-defendant to various locations. The Defendant and co-defendant physically attacked Rivera, causing injuries, and later used Rivera's car to make multiple attempts to strike the victims at a truck stop (paras 4-6).

Procedural History

• District Court of Bernalillo County: The Defendant was convicted of one count of aggravated battery with a deadly weapon and great bodily harm and three counts of aggravated assault with a deadly weapon.

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred in denying two motions for a mistrial, a motion for a new trial, and that there was insufficient evidence to support the convictions (headnotes, paras 1, 7, 22).
• Plaintiff-Appellee: Contended that the district court acted within its discretion in denying the motions and that sufficient evidence supported the convictions (headnotes, paras 1, 7, 22).

Legal Issues

• Did the district court err in denying the Defendant’s motions for a mistrial due to the co-defendant’s absence after jury selection?
• Did the district court err in denying the Defendant’s motion for a new trial based on alleged juror misconduct?
• Was there sufficient evidence to support the Defendant’s convictions for aggravated battery and aggravated assault?

Disposition

• The Court of Appeals affirmed the district court’s rulings on all issues (headnotes, para 38).

Reasons

Per Garcia J. (Wechsler and Bustamante JJ. concurring):

Motions for Mistrial:
The Defendant failed to demonstrate that the co-defendant’s absence after jury selection prejudiced the jury. The court instructed the jury not to speculate on the co-defendant’s absence, and jurors are presumed to follow such instructions. Speculative arguments about potential bias were insufficient to establish actual prejudice. The district court did not abuse its discretion in denying the motions for a mistrial (paras 8-15).

Motion for a New Trial:
The Defendant’s argument that jurors improperly considered his decision not to testify was unsupported by evidence. Juror statements about deliberations are inadmissible under Rule 11-606(B) NMRA unless they involve extraneous information, outside influence, or errors in the verdict form, none of which were present. The Defendant also failed to provide affidavits or a record of the hearing on the motion. The district court’s denial of the motion was not an abuse of discretion (paras 16-25).

Sufficiency of the Evidence:
The testimony of Rivera and Herrera provided substantial evidence to support the convictions. Rivera positively identified the Defendant as the driver and assailant, and her testimony was corroborated by Herrera. The absence of Hicks’ testimony and Herrera’s inability to conclusively identify the Defendant as the driver did not undermine the sufficiency of the evidence. The jury was entitled to weigh the evidence and make credibility determinations. The convictions were supported by sufficient evidence (paras 26-37).