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 arrested in Texas on January 5, 1992, for evading a police officer and being a fugitive from justice based on New Mexico charges of residential burglary and larceny. A "no bond" hold was placed on him for the New Mexico charges. On January 15, 1992, he was also booked on an unrelated Texas burglary charge, for which he could not post the $10,000 bond. The Texas charge was dismissed on December 7, 1992, after which the Defendant was extradited to New Mexico, where he pled guilty to residential burglary, and the larceny charge was dismissed as part of a plea agreement (paras 2-4).

Procedural History

• District Court of Dona Ana County: The trial court awarded the Defendant presentence confinement credit only from December 7, 1992, when the Texas charge was dismissed, to the date of sentencing, denying credit for the period from January 5, 1992, to December 7, 1992 (paras 4, 7).

Parties' Submissions

• Defendant-Appellant: Argued that he should receive presentence confinement credit from January 5, 1992, the date of his arrest in Texas, to the date of sentencing, as his confinement during this period was related to the New Mexico charges (paras 4, 7).
• Plaintiff-Appellee (State): Contended that the Defendant's confinement during this period was due to his inability to post bond on the unrelated Texas charge, not the New Mexico charges. The State argued that the "no bond" hold for the New Mexico charges did not affect the Defendant's ability to be released (para 6).

Legal Issues

• Was the Defendant entitled to presentence confinement credit for the period from January 5, 1992, to December 7, 1992, when he was held in custody in Texas on both New Mexico and unrelated Texas charges?

Disposition

• The Court of Appeals reversed the trial court's decision and remanded the case with instructions to credit the Defendant with presentence confinement from January 5, 1992, to December 7, 1992 (paras 7-9).

Reasons

Per Flores J. (Apodaca and Black JJ. concurring):

The Court held that under NMSA 1978, Section 31-20-12, presentence confinement credit must be awarded for time spent in official custody before the disposition of charges, as long as the confinement is related to the charge on which the conviction is based. The Court emphasized that the confinement need not relate exclusively to the charges for which credit is sought (paras 5-6).

The Court found that the Defendant was held in custody from January 5, 1992, due to the New Mexico charges, as evidenced by the "no bond" hold placed on him. Even though he was also held on an unrelated Texas charge, his confinement was still related to the New Mexico charges. The State's argument that the Defendant's inability to post bond on the Texas charge was the sole reason for his confinement was unpersuasive, as the "no bond" hold would have prevented his release regardless of the Texas bond (paras 6-7).

The Court concluded that the trial court erred in denying the Defendant presentence confinement credit for the period from January 5, 1992, to December 7, 1992, and ordered that the credit be applied (paras 7-8).