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, who suffers from severe asthma, was previously found to be at risk of life-threatening harm if incarcerated in the Grants Correctional Facility due to inadequate medical care. Despite this, the Defendant was arrested on May 14, 1992, for distributing marijuana and later pleaded no contest to the charge. At sentencing, the Defendant argued that incarceration in the Grants facility would still constitute cruel and unusual punishment due to her medical condition (paras 1-2).
Procedural History
- State v. Arrington, 115 N.M. 559, 855 P.2d 133 (Ct. App. 1993): The Court of Appeals affirmed the district court's decision that incarcerating the Defendant in the Grants Correctional Facility would constitute cruel and unusual punishment due to the facility's inability to provide adequate medical care for her severe asthma (para 2).
Parties' Submissions
- Defendant-Appellant: Argued that incarceration in the Grants Correctional Facility would constitute cruel and unusual punishment under the Eighth Amendment and the New Mexico Constitution due to the inadequacy of medical care for her severe asthma (paras 1, 4).
- Plaintiff-Appellee: Contended that the medical care available at the Grants facility, including access to physicians, nurses, and emergency services, was sufficient to address the Defendant's medical needs and did not amount to deliberate indifference (paras 5-6).
Legal Issues
- Whether incarcerating the Defendant in the Grants Correctional Facility constitutes cruel and unusual punishment under the Eighth Amendment and the New Mexico Constitution due to her severe asthma.
Disposition
- The Court of Appeals affirmed the district court's judgment and sentence, holding that incarceration in the Grants Correctional Facility would not constitute cruel and unusual punishment (para 7).
Reasons
Per Hartz J. (Donnelly and Pickard JJ. concurring):
The Court found that the evidence presented at the sentencing hearing differed from the prior case. Testimony established that the Grants facility had improved medical care arrangements, including access to a contract physician available 20 hours per week, five additional local physicians, registered and licensed nurses on duty at all times, and proximity to a hospital and ambulance services. These measures were deemed sufficient to address the Defendant's medical needs and did not amount to deliberate indifference (paras 5-6).
The Court distinguished the current case from the prior decision in State v. Arrington, noting that the State had now provided evidence rebutting claims of inadequate care. The Court also emphasized that constitutional standards do not require instantaneous access to a medical specialist. The Defendant retains the right to seek relief if the care provided in prison falls below constitutional standards in the future (paras 6-7).