AI Generated Opinion Summaries

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 charged with a felony in New Mexico and later pleaded guilty to a lesser offense. Before sentencing, the Defendant failed to appear and was subsequently found in custody in California, serving a sentence for an unrelated crime. A New Mexico detainer was lodged against him, which made his conditions of confinement in California more restrictive. Upon release from California custody, the Defendant was returned to New Mexico for sentencing (paras 2-3).

Procedural History

• District Court of Dona Ana County: Denied the Defendant's request for presentence confinement credit for the time spent in California custody after the New Mexico detainer was lodged (paras 1-2).

Parties' Submissions

• Defendant-Appellant: Argued that he should receive presentence confinement credit for the time spent in California custody after the New Mexico detainer was lodged, as the detainer made his conditions of confinement more onerous (paras 2-3).
• Plaintiff-Appellee: Contended that the Defendant was not entitled to credit for the California confinement because it was unrelated to the New Mexico charges (paras 2-3).

Legal Issues

• Whether the Defendant was entitled to presentence confinement credit for time spent in California custody after a New Mexico detainer was lodged (para 1).

Disposition

• The Court of Appeals affirmed the trial court's denial of presentence confinement credit for the time spent in California custody (para 6).

Reasons

Per Pickard J. (Alarid and Flores JJ. concurring):

The Court held that under NMSA 1978, Section 31-20-12, presentence confinement credit is only required when the fact of confinement is caused by or related to the charges for which the credit is sought. The Court reviewed prior case law and found that in cases where credit was granted, the confinement was directly caused by or related to the charges in question. Conversely, in cases where credit was denied, the confinement was unrelated to the charges (paras 1, 3-5).

In this case, the Defendant's California confinement was unrelated to the New Mexico charges, as there was no evidence that the California incarceration was caused by or connected to the New Mexico detainer. The mere fact that the detainer made the conditions of confinement more onerous did not trigger the application of Section 31-20-12. Therefore, the trial court's denial of credit was proper (paras 2-5).