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, a minor, was in custody at the Otero County Juvenile Detention Center. During an attempted escape, he struck a guard multiple times on the back of the head, causing temporary bruises and red marks on her head and neck. He was convicted of misdemeanor aggravated battery (paras 2-3).
Procedural History
- Children's Court of Otero County: The Defendant was convicted of misdemeanor aggravated battery and sentenced as a youthful offender, receiving an adult sentence (headnotes, para 1).
Parties' Submissions
- Defendant-Appellant: Argued that misdemeanor aggravated battery should not qualify as an offense subjecting a minor to youthful offender treatment under the statute, as it is the only misdemeanor included among otherwise felony offenses. Additionally, he contended that he lacked the intent to injure the guard (paras 2, 4, 7).
- Plaintiff-Appellee: Asserted that the plain language of the statute includes misdemeanor aggravated battery as a qualifying offense for youthful offender treatment. Further, intent to injure could be inferred from the Defendant's conduct and the surrounding circumstances (paras 3, 5, 7).
Legal Issues
- Whether misdemeanor aggravated battery qualifies as an offense that may subject a minor to youthful offender treatment under the statute.
- Whether there was sufficient evidence to establish the Defendant's intent to injure the guard (paras 3, 7).
Disposition
- The Defendant's conviction and sentence as a youthful offender were affirmed (para 8).
Reasons
Per Hartz J. (Apodaca C.J. and Black J. concurring):
- The court held that the plain language of the statute includes both misdemeanor and felony aggravated battery as qualifying offenses for youthful offender treatment. The legislature's intent is expressed through the statute's language, and there is no basis to exclude misdemeanor aggravated battery from the list of qualifying offenses (paras 3, 5).
- The court rejected the Defendant's argument that including misdemeanor aggravated battery leads to an unjust result. It noted that the statute grants courts discretion to impose either adult sentences or juvenile sanctions on youthful offenders, mitigating potential inequities (para 5).
- Regarding the Defendant's intent, the court found sufficient evidence to infer intent to injure. The Defendant struck the guard multiple times on the back of the head, causing visible injuries. The jury could reasonably conclude that the Defendant intended to harm the guard, despite his claim that he only wanted her to release the keys (para 7).
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