This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
On June 29, 1989, two brothers, Paul and Eric Mascarenas, were involved in a series of altercations outside a bar in Rodarte, New Mexico. Paul was attacked by a group of men, including the defendants, and was stabbed multiple times, resulting in his death. Eric was also assaulted but survived. The defendants were charged with aggravated battery, with the prosecution arguing they aided and abetted the attack on Paul (paras 4-8).
Procedural History
- District Court of Taos County: The defendants were convicted of aggravated battery with great bodily harm. Ortega was sentenced to three years imprisonment, suspended, with a condition to donate $500 to the Taos County Sheriff's Office (paras 1, 45-46).
Parties' Submissions
- Defendants (Appellants): Argued that the trial court erred by not requiring the state to provide racially neutral explanations for peremptory challenges against Hispanic jurors, denying their motion to sever trials, and refusing their requested jury instruction. Dominguez also argued insufficient evidence supported his conviction and that the grand jury indictment should have been dismissed. Ortega challenged the legality of his sentence (paras 2-3, 9-10, 26-27, 30-31, 36, 42, 45-46).
- State (Appellee): Contended that the defendants failed to establish a prima facie case of racial discrimination in jury selection, that the joint trial was proper, and that the jury instructions were adequate. The state also argued that sufficient evidence supported Dominguez's conviction and that the grand jury indictment was valid. Regarding Ortega's sentence, the state maintained the probation condition was lawful and related to rehabilitation (paras 12-13, 18-19, 28-29, 33-34, 40, 43, 46-47).
Legal Issues
- Did the trial court err in not requiring the state to provide racially neutral explanations for its peremptory challenges against Hispanic jurors?
- Was the denial of the defendants' motion to sever their trials from a co-defendant proper?
- Did the trial court err in refusing the defendants' requested jury instruction on aiding and abetting?
- Was there sufficient evidence to support Dominguez's conviction for aggravated battery?
- Did the trial court err in denying Dominguez's motion to dismiss the grand jury indictment?
- Was the probation condition requiring Ortega to donate $500 to the Taos County Sheriff's Office lawful?
Disposition
- The Court of Appeals affirmed the convictions of both defendants.
- The Court vacated the probation condition requiring Ortega to donate $500 to the Taos County Sheriff's Office and remanded for further sentencing proceedings (paras 3, 52-53).
Reasons
Per Apodaca J. (Donnelly and Chavez JJ. concurring):
Peremptory Challenges: The defendants failed to establish a prima facie case of racial discrimination under Batson v. Kentucky. The jury included a higher percentage of Hispanics than the venire, and the state did not use all its peremptory challenges. These factors negated any inference of purposeful discrimination (paras 12-25).
Motion to Sever: The joint trial was proper as the charges arose from a single incident, and the jury demonstrated its ability to differentiate between the defendants' culpability. The evidence against George Lopez would have been admissible in separate trials, and no prejudice was shown (paras 26-29).
Jury Instruction: The trial court properly refused the defendants' requested instruction on aiding and abetting, as the uniform jury instruction adequately covered the law. The requested instruction was potentially misleading and unnecessary (paras 30-35).
Sufficiency of Evidence: Substantial evidence supported Dominguez's conviction. Testimony indicated he participated in the attack on Paul Mascarenas, and his actions demonstrated intent to injure, satisfying the elements of aggravated battery (paras 36-41).
Grand Jury Indictment: Dominguez failed to show how his absence from the grand jury proceedings prejudiced him or would have changed the probable cause determination. The trial court did not err in denying his motion to dismiss the indictment (paras 42-44).
Ortega's Sentence: The probation condition requiring Ortega to donate $500 to the Taos County Sheriff's Office was unauthorized and void. The court lacked statutory authority to impose such a condition, and it was unrelated to Ortega's rehabilitation. The case was remanded for reconsideration of a valid fine not exceeding $500 (paras 45-51).