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 Child, who had been arrested on a charge of first-degree murder and detained in the Eddy County Detention Facility, escaped while being transported in a van. The Child unlocked his restraints using a stolen handcuff key and fled when the van door was opened by the transporting officer.

Procedural History

• District Court, Eddy County: The Child was convicted of escape from the custody of a peace officer.

Parties' Submissions

• Appellant (Child): Argued that he should have been charged with escape from the custody of the Children, Youth, and Families Department (CYFD) under NMSA 1978, § 30-22-11.1, rather than escape from the custody of a peace officer under NMSA 1978, § 30-22-10. The Child contended that his detention circumstances aligned with the statutory language for escape from CYFD custody.
• Appellee (State): Maintained that the charge of escape from the custody of a peace officer was appropriate because the Child had been bound over to district court to be tried as an adult and was detained in a county detention facility, not a juvenile detention facility.

Legal Issues

• Was the Child properly charged with escape from the custody of a peace officer under NMSA 1978, § 30-22-10, rather than escape from the custody of CYFD under NMSA 1978, § 30-22-11.1?

Disposition

• The Court of Appeals affirmed the Child’s conviction for escape from the custody of a peace officer.

Reasons

Per Bustamante J. (Fry CJ. and Robles J. concurring):

The Court found that the statutory language of NMSA 1978, § 30-22-10, which governs escape from the custody of a peace officer, applied to the Child’s circumstances. The Child had been arrested for a felony, bound over to district court to be tried as an adult, and detained in a county detention facility. The Court reasoned that these facts did not align with the statutory requirements for escape from CYFD custody under NMSA 1978, § 30-22-11.1, which applies to juveniles detained in juvenile facilities. The Court concluded that the charge and conviction under § 30-22-10 were appropriate and affirmed the decision of the lower court.