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 was stopped by a police officer for failing to use a turn signal. During the stop, the officer was informed by dispatch that there was a valid warrant for the Defendant's arrest due to a probation violation. The officer handcuffed the Defendant and attempted to place him in the patrol car, but the Defendant fled on foot. After a struggle, the Defendant was apprehended and later convicted of escape from the custody of a peace officer, a fourth-degree felony under NMSA 1978, Section 30-22-10 (1963).

Procedural History

• District Court, Curry County: The Defendant was convicted of escape from the custody of a peace officer pursuant to a conditional plea agreement. The Defendant's motion to dismiss was denied.

Parties' Submissions

• Appellant (Defendant): Argued that his conviction did not satisfy the elements of NMSA 1978, Section 30-22-10, as the probation violation underlying the arrest warrant was not a felony. He contended that the statute only applies to escapes from arrests for the commission or alleged commission of a felony and not for probation violations based on prior felony convictions.
• Appellee (State): Asserted that the probation violation was based on underlying felony offenses, and a common-sense reading of the statute includes escapes from arrests for probation violations tied to prior felonies. The State argued that the Defendant's interpretation would lead to an absurd result.

Legal Issues

• Does NMSA 1978, Section 30-22-10 apply to escapes from arrests for probation violations based on prior felony convictions?

Disposition

• The Court of Appeals affirmed the Defendant's conviction.

Reasons

Per Wechsler J. (Fry CJ. and Kennedy J. concurring):

The Court held that a common-sense interpretation of NMSA 1978, Section 30-22-10 includes escapes from arrests for probation violations tied to prior felony convictions. The statute criminalizes escapes from lawful arrests for the commission or alleged commission of a felony, and this includes arrests for probation violations based on underlying felonies. The Court rejected the Defendant's argument that the statute's language excludes such arrests, as this interpretation would lead to an absurd result. The Court also declined to address the Defendant's argument regarding the alleged deficiency of UJI 14-2223 NMRA, as no jury instruction was given in this case due to the conditional plea.