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 was involved in a domestic altercation with their spouse, during which the Defendant pushed the spouse in the course of an argument. The spouse subsequently told the Defendant to leave and called the police. The incident occurred in New Mexico between October 20 and 24, 2007 (paras headnotes, paras 2-3).
Procedural History
- District Court, Sandra A. Grisham, District Judge: The Defendant was convicted of battery on a household member and acquitted of possession of a firearm following a jury trial.
Parties' Submissions
- Appellant (Defendant): Argued that the evidence presented at trial was insufficient to support the conviction for battery on a household member, challenging the sufficiency of the evidence under the standard set forth in State v. Franklin and State v. Boyer (paras headnotes, paras 2-3).
- Appellee (State): Asserted that the evidence presented at trial, including testimony about the Defendant pushing the spouse during an argument, was sufficient to support the conviction (paras headnotes, paras 2-3).
Legal Issues
- Was there sufficient evidence to support the Defendant’s conviction for battery on a household member?
Disposition
- The Court of Appeals affirmed the Defendant’s conviction for battery on a household member.
Reasons
Per Michael E. Vigil J. (Bustamante and Garcia JJ. concurring):
The Court applied a two-step analysis to evaluate the sufficiency of the evidence. First, it viewed the evidence in the light most favorable to the guilty verdict, resolving all conflicts in favor of the verdict. Second, it determined whether the evidence could justify a finding by any rational trier of fact that each element of the crime was established beyond a reasonable doubt.
The Court found that the jury instructions required proof that the Defendant intentionally touched or applied force to the spouse in a rude, insolent, or angry manner. Testimony presented at trial indicated that the Defendant pushed the spouse during an argument, which the jury could reasonably infer was intentional and done in an angry manner. The Court concluded that this evidence constituted substantial evidence to support the conviction.
The Defendant’s memorandum in opposition did not present any new factual or legal arguments to challenge the Court’s proposed disposition. As a result, the Court remained unpersuaded and affirmed the conviction.