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, aged 15 at the time, was charged with over 20 offenses in 1994, including burglaries, vehicle theft, and a high-speed police chase. He pleaded guilty to two counts of aggravated burglary, one count of residential burglary, and no contest to one count of aggravated assault on a police officer (paras 2-3).
Procedural History
- District Court, July 1995: The Defendant was found not amenable to treatment or rehabilitation as a child and was sentenced as an adult to 24 years, with one-third suspended (para 3).
- Court of Appeals, March 4, 1997: The Court affirmed the Defendant's guilty plea but reversed the district court's amenability determination, remanding for re-analysis of the factors under Section 32A-2-20(C) (para 4).
- New Mexico Supreme Court, January 1998: The Court quashed the Defendant's writ of certiorari, and the case was remanded to the district court (para 5).
Parties' Submissions
- Defendant-Appellant: Argued that the delay in conducting the amenability hearing violated his constitutional right to speedy sentencing, due process rights, and the six-month rule. He also contended that the district court abused its discretion in finding him not amenable to treatment or rehabilitation as a child (paras 1, 8, 30, 36).
- Plaintiff-Appellee: Asserted that the Defendant waived his right to speedy sentencing by pleading guilty and requesting a continuance. The State also argued that the district court's findings on amenability were supported by evidence and should be upheld (paras 10-11, 36).
Legal Issues
- Did the delay in conducting the amenability hearing violate the Defendant's constitutional right to speedy sentencing?
- Did the delay violate the Defendant's due process rights?
- Was the six-month rule under Rule 5-604(B) applicable to the amenability hearing?
- Did the district court abuse its discretion in determining that the Defendant was not amenable to treatment or rehabilitation as a child?
Disposition
- The Court of Appeals affirmed the district court's Amended Judgment, Partially Suspended Sentence, and Commitment Upon Remand (para 38).
Reasons
Per Bosson J. (Armijo and Kennedy JJ. concurring):
Speedy Sentencing: Assuming the Sixth Amendment right to speedy trial applies to sentencing, the Court applied the four-factor test from Barker v. Wingo. While the nine-month delay was slightly longer than necessary to trigger inquiry, the Defendant failed to demonstrate substantial prejudice caused by the delay. The district court's decision was based on multiple factors, most of which were unaffected by the delay (paras 16-29).
Due Process: The Defendant did not prove actual and substantial prejudice or intentional delay by the State to gain a tactical advantage. Thus, his due process claim failed (para 30).
Six-Month Rule: Rule 5-604(B) applies only to trials and habitual criminal proceedings, not to sentencing hearings. The Court declined to extend its application to the amenability hearing (paras 31-34).
Amenability Determination: The district court did not abuse its discretion in finding the Defendant not amenable to treatment or rehabilitation as a child. The court's findings on five of the six statutory factors were supported by substantial evidence, and the Defendant's arguments did not undermine the court's reasoning (paras 36-37).