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 convicted of heroin possession and classified as a habitual offender. As part of a plea agreement, her sentence was partially suspended on the condition that she complete an in-house drug rehabilitation program at Delancey Street following her release from prison. The Defendant later sought to have this condition removed, arguing it violated her constitutional rights (paras 2-4).
Procedural History
- District Court, September 27, 1993: The court modified the Defendant's probation conditions, removing the Delancey Street requirement and replacing it with attendance at Alcoholics Anonymous and Narcotics Anonymous meetings, periodic evaluations, and compliance with treatment recommendations. The court did not find the original condition unconstitutional but determined it had the authority to modify probation terms (paras 1, 4-5).
Parties' Submissions
- Appellant (State of New Mexico): Argued that the district court lacked authority to modify the probation conditions, as the original condition was part of a valid plea agreement. The State contended that no statutory or procedural basis justified the modification (paras 6-7).
- Appellee (Defendant): Asserted that the district court had discretion to modify probation conditions under applicable statutes and rules, and that the habeas corpus petition could be treated as a motion to modify the sentence (paras 6, 10-12).
Legal Issues
- Did the district court have the authority to modify the Defendant's probation conditions?
- If such authority existed, did the district court abuse its discretion in modifying the probation conditions?
Disposition
- The Supreme Court of New Mexico reversed the district court's order modifying the probation conditions and remanded the case for reinstatement of the original sentence and conditions (paras 15-16).
Reasons
Per Baca J. (Montgomery C.J. and Ransom J. concurring):
The Court held that the district court lacked authority to modify the probation conditions under the statutes and rules cited by the Defendant. Specifically:
Section 31-21-15(B): This statute allows modification of probation only in cases of probation violations, which were not present in this case (para 8). SCRA 5-802: The habeas corpus rule requires a constitutional or legal violation to grant relief, which was not established here (para 9). SCRA 5-801(B): The rule requires motions to modify a sentence to be filed within 90 days of sentencing. The Defendant's petition was filed well beyond this period, and no extension was granted under SCRA 5-104(B)(2) (paras 10-12). Section 31-21-21: While this statute grants courts discretion to modify probation conditions, the Court found that the district court abused its discretion by altering a condition that was part of a valid plea agreement. Modifying the condition allowed the Defendant to retain the benefits of the plea agreement without fulfilling her obligations, which violated principles of fairness and mutuality in plea bargaining (paras 13-15).
The Court emphasized that plea agreements are binding on both parties, and absent a mutual agreement to modify the terms, the district court could not unilaterally alter the conditions. The original probation condition requiring completion of the Delancey Street program was reinstated (paras 14-16).