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 pleaded guilty to a third offense of aggravated driving while intoxicated (DWI) and driving with a revoked license. The magistrate court sentenced the Defendant to 364 days in jail for the DWI charge, suspending 274 days, and imposed a 90-day mandatory jail term. The Defendant completed a 106-day in-patient alcohol treatment program and sought presentence credit for the time spent in treatment, which the magistrate court granted, substituting the treatment for the mandatory jail term (paras 1-4).

Procedural History

• Magistrate Court: Granted the Defendant's motion to amend the sentence, allowing 106 days of in-patient alcohol treatment as credit for the 90-day mandatory jail term (paras 4-5).
• District Court: Affirmed the magistrate court's decision, concluding that court-ordered in-patient treatment constitutes official confinement for purposes of presentence credit (para 5).
• Court of Appeals: Certified the matter to the Supreme Court of New Mexico, raising the issue of whether trial courts have the authority to grant presentence confinement credit for misdemeanors (para 6).

Parties' Submissions

• State (Appellant): Argued that the magistrate court erred in substituting in-patient alcohol treatment for the mandatory 90-day jail term, as it violated the Legislature's intent under Section 66-8-102(F)(2) (paras 5-6, 16-18).
• Defendant (Appellee): Contended that the magistrate court had the discretion to grant presentence confinement credit for in-patient alcohol treatment and that such treatment constituted official confinement (paras 5-6, 14).

Legal Issues

• Do trial courts have the authority to grant presentence confinement credit for in-patient alcohol treatment in cases involving a third offense of aggravated DWI?
• Does substituting in-patient alcohol treatment for a mandatory jail term violate the Legislature's intent under Section 66-8-102(F)(2)?

Disposition

• The Supreme Court of New Mexico reversed the amended sentence and remanded the case with instructions to reinstate the mandatory 90-day jail term (para 21).

Reasons

Per Minzner J. (Franchini C.J., Baca, Serna, and McKinnon JJ. concurring):

• The Court held that trial courts possess inherent discretionary authority to grant presentence confinement credit, provided it does not interfere with the Legislature's authority to establish criminal penalties (para 1, 14).
• The Legislature's intent under Section 66-8-102(F)(2) was clear: a mandatory 90-day jail term for third-offense aggravated DWI offenders cannot be suspended, deferred, or substituted with other forms of punishment, including in-patient alcohol treatment (paras 16-18).
• The magistrate court's substitution of alcohol treatment for jail conflicted with the Legislature's intent to impose distinct and separate penalties for jail time and alcohol treatment (paras 16-18).
• The Court emphasized that while trial courts have discretion to grant presentence confinement credit, such credit must not undermine mandatory minimum sentences established by the Legislature (paras 14, 18-19).
• The Court concluded that the magistrate court erred in granting credit for in-patient alcohol treatment in lieu of the mandatory jail term and remanded the case for reinstatement of the original sentence (paras 21-22).