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 found guilty but mentally ill of first-degree murder, three counts of attempted murder, and two counts of aggravated battery. The Defendant sought to modify her sentence to be placed in a mental health facility for treatment, citing her mental illness, rather than serving her sentence in a corrections facility.
Procedural History
- State v. Neely, 1991: The Supreme Court of New Mexico upheld the Defendant's convictions and the statutory scheme authorizing the "guilty but mentally ill" verdict (Neely I).
Parties' Submissions
- Appellant (Defendant): Argued that the trial court had discretion to modify her sentence to allow placement in a mental health facility for treatment, rather than incarceration in a corrections facility.
- Appellee (State): Contended that the trial court lacked discretion to modify a mandatory life sentence for first-degree murder and that the Defendant's motion was an improper challenge to the legality of her sentence.
Legal Issues
- Did the trial court have jurisdiction to hear the Defendant's motion to modify her sentence?
- Was the trial court's denial of the Defendant's motion to modify her sentence proper?
- Does a sentencing court have discretion to sentence a defendant found guilty but mentally ill of a first-degree felony to a mental health facility instead of a corrections facility?
Disposition
- The Supreme Court of New Mexico affirmed the trial court's denial of the Defendant's motion to modify her sentence.
Reasons
Per Ransom J. (Baca, Franchini, and Montgomery JJ. concurring):
The Court held that the trial court had subject-matter jurisdiction to hear the Defendant's motion under Rule 5-801, as the motion was filed within the prescribed time frame after the appellate mandate. The denial of the motion was deemed a final, appealable order, and the Defendant properly preserved the issue for review.
The Court determined that the trial court lacked discretion to modify the Defendant's mandatory life sentence for first-degree murder. Under New Mexico law, sentencing courts cannot suspend, defer, or reduce sentences for first-degree felonies, including capital felonies. The statutory scheme for "guilty but mentally ill" defendants does not override this limitation. Instead, the responsibility for providing mental health treatment lies with the corrections department, not the sentencing court.
Special Concurrence by Montgomery C.J.:
Chief Justice Montgomery reluctantly concurred, agreeing that the trial court lacked discretion to modify the mandatory life sentence. However, he criticized the inconsistency between this decision and the rationale in Neely I, which suggested that the "guilty but mentally ill" verdict allowed for judicial discretion in sentencing. He expressed concern that the verdict misleads jurors into believing it results in leniency or treatment, which it does not.