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 case concerns the revocation of the driving privileges of the Petitioner, who had received a third DWI citation in February 1996. The magistrate court initially found the Petitioner guilty and sentenced her, but later amended its judgment to dismiss the DWI charge after the Petitioner complied with court-ordered conditions. The Motor Vehicle Division (the Division) refused to reinstate the Petitioner’s driving privileges despite the amended judgment, leading to the Petitioner seeking judicial review in the district court (paras 2-6).
Procedural History
- Magistrate Court, February 1996: Found the Petitioner guilty of a third DWI offense and sentenced her to 90 days in jail, with 87 days suspended (para 2).
- Magistrate Court, Date Unspecified: Amended its judgment to dismiss the DWI charge after the Petitioner complied with court-ordered conditions (para 4).
- District Court, March 1997: Ordered the reinstatement of the Petitioner’s driving privileges (para 8).
Parties' Submissions
- Appellant (Motor Vehicle Division): Argued that the district court lacked jurisdiction to hear the Petitioner’s untimely petition, that the magistrate court lacked authority to amend its original judgment, and that the amended judgment had no effect on the Division’s records for license revocation purposes (para 1).
- Appellee (Petitioner): Contended that the Division was required to honor the magistrate court’s amended judgment dismissing the DWI charge and reinstating her driving privileges (para 8).
Legal Issues
- Did the district court have jurisdiction to hear the Petitioner’s untimely petition for judicial review?
- Did the magistrate court have the authority to amend its original judgment to dismiss the DWI charge?
- Did the magistrate court’s amended judgment affect the Division’s records for license revocation purposes?
Disposition
- The Court of Appeals reversed the district court’s order reinstating the Petitioner’s driving privileges (para 14).
Reasons
Per Apodaca J. (Flores and Armijo JJ. concurring):
The Court of Appeals raised the issue of jurisdiction sua sponte, finding that the Petitioner failed to properly invoke the district court’s jurisdiction. The Petitioner’s filing did not meet the procedural requirements for a writ of certiorari, which was the appropriate method of review for a mandatory license revocation. The Court emphasized that jurisdictional defects cannot be waived and must be addressed even if not raised by the parties. Consequently, the district court’s order was reversed without addressing the other issues raised by the Division (paras 9-14).