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 convicted of aggravated driving while under the influence of intoxicating liquor (aggravated DWI) and improper backing of a vehicle. These charges arose from an incident where the Defendant was found to have violated traffic laws. The case was remanded for a new trial after the initial conviction was reversed due to improper jury voir dire questioning by the State (paras 1-2).

Procedural History

• Court of Appeals, November 1999: The Defendant was convicted of aggravated DWI and improper backing of a vehicle.
• Court of Appeals, May 2000: The Court reversed the Defendant's convictions due to improper jury voir dire questioning by the State and remanded the case for a new trial (paras 2-3).

Parties' Submissions

• Defendant-Appellant: Argued that the State violated Rule 5-604 NMRA 2003 by failing to bring the case to trial within six months of the mandate being filed with the district court. The Defendant also claimed a violation of his Sixth Amendment right to a speedy trial (paras 1, 3).
• Plaintiff-Appellee (State): Contended that the delay in trial was attributable to the Defendant, as the local rule (LR3-215 NMRA 2003) required the Defendant, as the prevailing party on appeal, to file the judgment on mandate to reinstate proceedings. The State argued that this local practice shifted responsibility to the Defendant (paras 3, 6).

Legal Issues

• Did the State violate Rule 5-604 NMRA 2003 by failing to bring the Defendant to trial within six months of the mandate being filed with the district court?
• Was the Defendant's Sixth Amendment right to a speedy trial violated?
• Does the local rule (LR3-215 NMRA 2003) apply to criminal cases, thereby requiring the Defendant to file the judgment on mandate?

Disposition

• The Court of Appeals reversed the district court's decision, finding that the State failed to bring the Defendant to trial within the required six-month period under Rule 5-604 NMRA 2003 (para 12).

Reasons

Per Wechsler CJ (Fry and Robinson JJ. concurring):

• The Court held that Rule 5-604(B)(4) mandates that a criminal trial must commence within six months of the mandate being filed with the district court. The rule is a bright-line standard designed to ensure the prompt disposition of criminal cases (paras 4, 12).
• The Court rejected the State's argument that the Defendant was responsible for the delay due to a local rule (LR3-215 NMRA 2003). It found that LR3-215 was listed under the "Civil Matters" section of the local rules and did not apply to criminal cases. Furthermore, the rule was not properly published or approved for application to criminal cases, and the Defendant was not given adequate notice of any such local practice (paras 7-10).
• The Court emphasized that the State bears the primary responsibility for bringing a criminal defendant to trial and that the Defendant had no duty to initiate proceedings against himself (paras 10-11).
• Since the State failed to comply with Rule 5-604, the Court reversed the district court's decision and dismissed the charges. The Court did not address the Sixth Amendment speedy trial claim, as the Rule 5-604 violation was dispositive (paras 12-13).