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 two counts of third-degree criminal sexual penetration, one count of robbery, and one count of unlawful taking of a vehicle, involving two victims, R.M. and F.C. The incidents occurred five days apart in Albuquerque, where the Defendant allegedly accosted the victims in their cars, forced them to have sex, and took their vehicles. The Defendant claimed the encounters were consensual and involved trading drugs for sex (paras 1-2).

Procedural History

• District Court, Bernalillo County: The Defendant was convicted of two counts of third-degree criminal sexual penetration, one count of robbery, and one count of unlawful taking of a vehicle. He was acquitted of kidnapping, second-degree criminal sexual penetration, bribery of a witness, and other related charges (headnotes, para 1).

Parties' Submissions

• Defendant-Appellant: Argued that the trial court erred in denying his motions to sever the charges related to each victim, claiming that the joinder of charges prejudiced his defense. He also raised other issues on appeal, most of which were deemed frivolous (para 1).
• Plaintiff-Appellee: Contended that the charges were properly joined as they were of similar character and that evidence of each incident was admissible in a joint trial. The State argued that the jury's ability to acquit the Defendant on some charges demonstrated a lack of prejudice (paras 3, 18).

Legal Issues

• Whether the trial court erred in denying the Defendant's motions to sever the charges related to each victim (para 1).
• Whether evidence of one incident was admissible in the trial of the other under Rule 11-404(B) of the New Mexico Rules of Evidence (paras 3-4).

Disposition

• The Court of Appeals reversed the Defendant's convictions and remanded the case for new trials (para 19).

Reasons

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

• The Court found that the trial court abused its discretion in denying the Defendant's motions to sever the charges. The evidence of each incident was inadmissible in the trial of the other under Rule 11-404(B) because it was used to show propensity, which is prohibited (paras 3-4, 13).
• The Court emphasized that Rule 11-404(B) requires a detailed analysis to determine whether evidence of other bad acts is admissible for a proper purpose, such as intent or knowledge, rather than to show character or propensity. In this case, the evidence did not meet these criteria (paras 5-13).
• The Court rejected the State's argument that the jury's acquittals on some charges demonstrated a lack of prejudice, noting that the improper admission of other-crimes evidence under Rule 11-404(B) inherently prejudices the Defendant when convictions are obtained (para 18).
• The Court concluded that the trial court's failure to grant the Defendant's renewed motion for severance during the trial, when the grounds for severance became more apparent, constituted reversible error (para 17).