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 Christmas Eve 1992, the Defendant drove the wrong way on Interstate 40 at a high speed while intoxicated, colliding with another vehicle. The crash resulted in the deaths of a mother and her three children and left the father severely injured. The Defendant was arrested at the scene and charged with multiple counts of vehicular homicide and great bodily injury by vehicle under both driving-while-intoxicated (DWI) and reckless-driving theories (paras 2-3).
Procedural History
- State v. House, 1999-NMSC-14, 127 N.M. 151, 978 P.2d 967: The New Mexico Supreme Court affirmed the Defendant's convictions but remanded the case for reformation of the sentence due to double jeopardy concerns (para 1).
- District Court, April 1999: On remand, the district court vacated the reckless-driving-based convictions to cure the double jeopardy violation but retained the DWI-related convictions and the original 25-year sentence (para 7).
Parties' Submissions
- Appellant (Defendant): Argued that the vehicular homicide statute is ambiguous regarding the priority of DWI-related versus reckless-driving-related offenses, the appropriate unit of prosecution, and the enhancement provision. He also claimed that the enhancement provision violated equal protection and due process and that the trial judge should have recused himself (paras 8, 14, 25, 31, 38, 40).
- Appellee (State): Contended that the doctrine of law of the case barred the Defendant's appeal and that the district court's actions, including the sentence enhancement and denial of the recusal motion, were proper (paras 7, 9-13).
Legal Issues
- Was the vehicular homicide statute ambiguous regarding the priority of DWI-related versus reckless-driving-related offenses?
- Did the statute fail to define the appropriate unit of prosecution, leading to multiple convictions for a single act of unlawful driving?
- Was the enhancement provision of the statute unconstitutionally ambiguous or in violation of equal protection and due process?
- Did the district court err in denying the Defendant's motion to recuse the trial judge?
Disposition
- The Court of Appeals affirmed the district court's judgment and the Defendant's 25-year sentence (para 42).
Reasons
Per Armijo J. (Pickard CJ and Bustamante J. concurring):
Jurisdiction and Law of the Case: The Court held that it had jurisdiction to hear the appeal, as the issues raised were not specifically ruled upon in prior proceedings. The doctrine of law of the case did not preclude review (paras 9-13).
Priority of Offenses: The Court found that the vehicular homicide statute established a hierarchy, with DWI-related offenses taking precedence over reckless-driving-related offenses due to the enhanced penalties for recidivist DWI offenders. The district court properly retained the DWI-related convictions (paras 14-16).
Unit of Prosecution: The Court rejected the Defendant's argument that the statute was ambiguous regarding the unit of prosecution. It held that each death constituted a separate offense under the statute, consistent with the majority rule and New Mexico law (paras 17-24).
Sentence Enhancement: The Court determined that the enhancement provision was not ambiguous and that the district court correctly applied a two-year enhancement to each of the Defendant's five convictions. The enhancement was consistent with legislative intent and did not violate equal protection or due process (paras 25-30, 32-38).
Recusal Motion: The Court deemed the Defendant's challenge to the denial of his motion to recuse the trial judge waived due to insufficient briefing and lack of substantive argument (para 40).
Constitutional Doubt: The Court found that the Defendant's invocation of the doctrine of constitutional doubt was inadequately briefed and therefore waived (para 41).