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 operating a John Deere tractor with an attached rotary mower on the side of a non-paved county roadway. While mowing weeds, the tractor snagged a fence, uprooting a mailbox. A sheriff's deputy stopped the Defendant, who exhibited signs of intoxication, including difficulty dismounting the tractor and a strong odor of alcohol. The Defendant admitted to consuming approximately ten beers (para 2).
Procedural History
- Magistrate Court: The Defendant was convicted of driving while intoxicated (DWI) (para 2).
- District Court: The Defendant's conviction was overturned, and the complaint was dismissed on the basis that a farm tractor is not a "vehicle" under the DWI statute (para 2).
Parties' Submissions
- Plaintiff-Appellant (State of New Mexico): Argued that a farm tractor qualifies as a "vehicle" under the DWI statute, as it is self-propelled and capable of being used on a highway. The State emphasized that the statute's language applies to "any vehicle" and does not limit its application to specific types of vehicles or their primary use (paras 3-5, 7-10).
- Defendant-Appellee: Contended that a farm tractor, primarily used for agricultural purposes off highways, does not fall under the definition of a "vehicle" in the DWI statute. The Defendant relied on prior case law to argue that the statute should not apply to devices not typically or lawfully used on highways (paras 6, 11-13).
Legal Issues
- Does a farm tractor with an attached mower qualify as a "vehicle" under the DWI statute? (para 1).
Disposition
- The Court of Appeals reversed the District Court's dismissal of the complaint and remanded the case for further proceedings (para 14).
Reasons
Per Apodaca J. (Donnelly J. concurring):
The Court held that a farm tractor with an attached mower is a "vehicle" under the DWI statute. The reasoning was based on the statutory definitions in the Motor Vehicle Code, which define "vehicle" broadly to include any device capable of transporting persons or property on a highway, and "motor vehicle" as a subset of "vehicle" that is self-propelled. Since a farm tractor is explicitly defined as a motor vehicle in the Code, it necessarily qualifies as a vehicle under the DWI statute (paras 3-5).
The Court rejected the Defendant's argument that the statute applies only to vehicles primarily used on highways, noting that the statute's language is clear and unambiguous, encompassing all vehicles regardless of their primary function or frequency of highway use (paras 6-8). The Court also emphasized that the legislative intent behind the DWI statute is to prevent impaired individuals from operating any vehicle, as such conduct poses significant safety risks (paras 8-9).
The Court further reasoned that the legislature's decision to exempt farm tractors from certain provisions of the Motor Vehicle Code, but not from the DWI statute, indicates an intent to include them within the statute's scope (para 10). The Defendant's reliance on prior case law was distinguished, as those cases involved devices not lawfully used on highways or addressed different statutory schemes (paras 11-13).
Per Hartz J., specially concurring:
Hartz J. agreed with the result and most of the reasoning but found the policy argument regarding the dangers of farm tractors veering into traffic unnecessary. He emphasized that the statutory language alone sufficiently supports the conclusion that a farm tractor is a vehicle under the DWI statute (para 16).