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 rented a motel room and a vehicle, which was later found to contain large quantities of iodine, a key ingredient in manufacturing methamphetamine. Inside the motel room, officers discovered over 5000 pseudoephedrine pills, acetone, and other materials associated with methamphetamine production. The Defendant admitted to smoking methamphetamine in the room and acknowledged knowledge of the materials' use in manufacturing methamphetamine (paras 2-3, 7-10).
Procedural History
- District Court, Curry County: The Defendant was convicted of attempted trafficking in methamphetamine by manufacture and possession of drug paraphernalia. The possession of methamphetamine charge was dismissed before trial (headnotes, para 3).
Parties' Submissions
- Defendant-Appellant: Argued that the evidence was insufficient to support her conviction for attempted trafficking in methamphetamine by manufacture, claiming that she did not take any substantial step toward manufacturing and that her actions amounted to mere preparation. She also contended that the materials found were insufficient to initiate manufacturing (paras 1, 6, 20, 22).
- Plaintiff-Appellee: Asserted that the Defendant's possession of materials necessary for methamphetamine production, her actions in renting the motel room and vehicle, and her inconsistent statements demonstrated a substantial step toward manufacturing methamphetamine and established the requisite intent (paras 15-16, 24-25).
Legal Issues
- Was there sufficient evidence to support the Defendant's conviction for attempted trafficking in methamphetamine by manufacture?
- Did the Defendant's actions constitute a substantial step toward the manufacture of methamphetamine?
- Was there sufficient evidence to establish the Defendant's intent to manufacture methamphetamine?
Disposition
- The Court of Appeals of New Mexico affirmed the Defendant's convictions for attempted trafficking in methamphetamine by manufacture and possession of drug paraphernalia (para 27).
Reasons
Per Wechsler J. (Pickard and Castillo JJ. concurring):
The Court held that the evidence was sufficient to support the Defendant's conviction. The possession of over 5000 pseudoephedrine pills, acetone, and iodine, combined with the Defendant's actions in renting the motel room and vehicle, constituted a substantial step toward manufacturing methamphetamine. The Court emphasized that even slight acts in furtherance of the crime could qualify as an attempt (paras 14-15, 21-23).
The Court rejected the Defendant's argument that the lack of all necessary materials for manufacturing methamphetamine precluded a conviction, noting that a full working lab is not required for an attempt conviction. The Defendant's inconsistent statements and her knowledge of the materials' use in methamphetamine production further supported the jury's finding of intent (paras 22-24).
Additionally, the Court found that the Defendant could be convicted under a theory of accomplice liability, as her actions in providing the vehicle and motel room, along with her behavior and statements, demonstrated that she helped, encouraged, or caused the attempt to manufacture methamphetamine (paras 25-26).