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 driving while intoxicated (DWI) and child endangerment after being stopped while driving with her six-year-old daughter in the car. The Defendant admitted to consuming alcohol, including five beers and tequila, prior to driving and acknowledged that her actions were dangerous (paras 1, 14).
Procedural History
- District Court of San Juan County: Convicted the Defendant of DWI and child endangerment.
Parties' Submissions
- Defendant-Appellant: Argued that (1) a peremptory strike by the State was improperly exercised based on race, (2) the district court erred in excluding portions of expert testimony regarding alcohol absorption and elimination rates, (3) the jury instructions on DWI were improper, and (4) the evidence was insufficient to support the child endangerment conviction (paras 2, 3, 6, 11, 13).
- Plaintiff-Appellee: Contended that (1) the peremptory strike was race-neutral and valid, (2) the expert testimony was properly excluded as irrelevant under the amended DWI statute, (3) the jury instructions conformed to the statutory requirements, and (4) the evidence was sufficient to support the child endangerment conviction (paras 3-5, 7-9, 11-14).
Legal Issues
- Was the State’s peremptory strike of a juror improperly based on race?
- Did the district court err in excluding portions of the Defendant’s expert witness testimony?
- Were the jury instructions on DWI improper?
- Was there sufficient evidence to support the Defendant’s conviction for child endangerment?
Disposition
- The Court of Appeals affirmed the Defendant’s convictions for DWI and child endangerment (para 16).
Reasons
Per Castillo J. (Fry C.J. and Bustamante J. concurring):
Peremptory Strike: The Court found that the State provided a race-neutral explanation for the peremptory strike, as the juror’s son had been convicted of DWI. The Defendant failed to refute this explanation or prove purposeful discrimination. The district court’s acceptance of the explanation was upheld (paras 3-5).
Exclusion of Expert Testimony: The Court held that the district court properly excluded expert testimony on alcohol absorption and elimination rates because the recent amendment to the DWI statute rendered such evidence irrelevant when test results are obtained within three hours of driving. The Defendant failed to demonstrate how the excluded testimony was relevant to the accuracy of the test results (paras 6-10).
Jury Instructions: The Court determined that the jury instructions conformed to the statutory definition of the offense. Minor deviations from the uniform jury instructions were immaterial, as the timing of alcohol consumption was undisputed (paras 11-12).
Sufficiency of Evidence for Child Endangerment: The Court concluded that substantial evidence supported the child endangerment conviction. The Defendant’s admission of drinking excessively before driving, combined with the presence of her child in the car, demonstrated reckless disregard for the child’s safety. The Court rejected the argument that actual harm or likelihood of harm was required for conviction (paras 13-15).