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 stopped by law enforcement in May 2008 for driving without headlights at night. Upon investigation, it was discovered that the Defendant's license had been revoked following a 2007 arrest for aggravated DWI, during which he refused a breath test. The Defendant had obtained an interlock license and an interlock device after the arrest but was driving a vehicle without an interlock device at the time of the stop. The Defendant admitted to the officer that his license was "no good" and presented an Arkansas license instead.
Procedural History
- District Court, Bernalillo County: The Defendant was convicted of driving with a revoked license.
Parties' Submissions
- Defendant-Appellant: Argued that there was insufficient evidence to prove he knew or should have known his license was revoked. He claimed that the Motor Vehicle Division (MVD) did not send him a formal notice of revocation after his 2007 arrest and that the statutory requirements for interlock licenses were ambiguous, leading to confusion about his license status.
- Plaintiff-Appellee: Contended that the Defendant had actual knowledge of his license revocation, as evidenced by the handwritten Notice of Revocation delivered to him in 2007, his signed affidavit acknowledging the consequences of driving without an interlock device, and his admission to the officer during the 2008 stop.
Legal Issues
- Was there sufficient evidence to prove beyond a reasonable doubt that the Defendant knew or should have known his license was revoked?
Disposition
- The Court of Appeals affirmed the Defendant's conviction for driving with a revoked license.
Reasons
Per Bustamante J. (Sutin and Robles JJ. concurring):
The Court held that sufficient evidence supported the Defendant's conviction. The handwritten Notice of Revocation delivered to the Defendant in 2007, combined with his signed affidavit acknowledging the consequences of driving without an interlock device, demonstrated that the Defendant had actual knowledge of his license revocation. Additionally, the Defendant's admission during the 2008 traffic stop that his license was "no good" further supported this conclusion. The Court rejected the Defendant's arguments regarding statutory ambiguity and lack of formal notice, noting that these issues were not preserved at trial and that the evidence overwhelmingly established the Defendant's knowledge of the revocation.