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

Law enforcement officers used a confidential informant (CI) to conduct a controlled purchase of methamphetamine from the Defendant. The CI was searched, equipped with a sound transmitter, and emerged from the Defendant’s residence with 5.2 grams of methamphetamine. The CI was paid for her participation. The State disclosed the CI’s identity as it intended to call her as a witness at trial (paras 1-2).

Procedural History

• District Court, San Juan County: The court ordered the State to disclose information about the CI’s prior work as an informant. When the State refused, the court excluded the CI’s testimony at trial (paras 1, 5).

Parties' Submissions

• Appellant (State): Argued that the district court erred in ordering discovery of the CI’s prior work and in excluding her testimony. Claimed the requested information was irrelevant, disclosure could endanger the CI, and the Defendant failed to show how the information was necessary for his defense (paras 3, 8-10).
• Appellee (Defendant): Contended that the requested information was necessary to challenge the CI’s credibility, as her testimony was central to the State’s case. Argued that the district court’s discovery order was reasonable and protective measures were in place to safeguard the CI’s identity (paras 3, 8-10).

Legal Issues

• Did the district court abuse its discretion in ordering the State to disclose information about the CI’s prior work as an informant?
• Did the district court abuse its discretion in excluding the CI’s testimony after the State refused to comply with the discovery order?

Disposition

• The Court of Appeals affirmed the district court’s decision, finding no abuse of discretion in either the discovery order or the exclusion of the CI’s testimony (paras 1, 14).

Reasons

Per Vigil J. (Pickard and Robinson JJ. concurring):

• The district court acted within its discretion in ordering discovery. Rule 5-503(C) NMRA allows discovery of information reasonably calculated to lead to admissible evidence. The CI was a key eyewitness, and the requested information could be relevant to impeaching her credibility. Protective measures were imposed to safeguard the CI’s identity (paras 6-10).
• The exclusion of the CI’s testimony was a permissible sanction for the State’s refusal to comply with the discovery order. The Defendant’s right to cross-examine and challenge the credibility of the State’s sole eyewitness was critical. The district court’s decision was consistent with Rule 5-503.2(B)(2) NMRA, which allows sanctions for noncompliance with discovery orders (paras 12-13).