This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
A juvenile, referred to as "Child," entered a plea agreement for aggravated battery with a deadly weapon and was sentenced to two years in the custody of the New Mexico Youth Authority. The Child filed a motion to reconsider the sentence, which was heard 132 days after filing, despite Rule 10-230.1(B) requiring such motions to be determined within 90 days or deemed denied by operation of law. The children's court reduced the sentence to one year, prompting the State to appeal (paras 1-3).
Procedural History
- Children's Court, April 18, 2000: Sentenced the Child to two years in custody for aggravated battery with a deadly weapon (para 2).
Parties' Submissions
- Appellant (State): Argued that Rule 10-230.1(B) mandates that motions to reconsider must be decided within 90 days of filing, or they are deemed denied. The children's court lacked authority to act on the motion after the 90-day period expired (paras 1, 4).
- Respondent (Child): Contended that the children's court had discretion to extend the 90-day period, citing due process concerns and the absence of a statutory time limit in the Children's Code. The Child also argued that the court had invited the reconsideration and that the rule conflicted with the statute (paras 5, 10-12).
Legal Issues
- Does Rule 10-230.1(B) require that motions to reconsider a juvenile's sentence be determined within 90 days, or are they deemed denied by operation of law?
- Does the children's court have discretion to extend the 90-day period for good cause?
- Does Rule 10-230.1(B) conflict with the Children's Code, and if so, which prevails?
Disposition
- The Court of Appeals reversed the children's court's order reducing the Child's sentence and reinstated the original two-year sentence (paras 17-18).
Reasons
Per Castillo J. (Bosson CJ. and Alarid J. concurring):
Application of Rule 10-230.1(B): The court held that the plain language of Rule 10-230.1(B) is unambiguous and requires motions to reconsider to be determined within 90 days of filing, or they are deemed denied. The children's court exceeded its authority by acting on the motion after the 90-day period expired (paras 4, 17).
Discretion to Extend Time: The court rejected the Child's argument that the children's court had discretion to extend the 90-day period. Unlike in prior cases where extensions were granted for good cause, no continuance or motion to enlarge time was filed in this case. The record did not support the claim that the court invited the reconsideration or delayed the hearing to gather additional information (paras 6-10).
Due Process: The court found no due process violation, distinguishing this case from precedent where courts created an expectation that motions would be heard. Here, the children's court did not create such an expectation, and the Child's argument lacked factual support (para 11).
Conflict Between Rule and Statute: The court determined that Rule 10-230.1(B) does not conflict with the Children's Code. While the statute does not impose a time limit, the rule's 90-day limit is a reasonable procedural requirement that does not contravene legislative intent. Procedural rules generally prevail over conflicting statutes (paras 12-15).
Conclusion: The court reinstated the original two-year sentence, emphasizing the mandatory nature of the 90-day limit under Rule 10-230.1(B) (paras 17-18).