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 two fourth-degree felonies—possession of a stolen vehicle and contributing to the delinquency of a minor—and a misdemeanor for concealing identity. The Defendant was sentenced to consecutive terms for these offenses, totaling three years of incarceration, with parole periods attached to the felony sentences. After serving the incarceration term for the first felony, the Defendant began serving parole for that offense concurrently with the incarceration term for the second felony. The State later sought to impose habitual offender enhancements on both felony convictions (paras 2-3).

Procedural History

• District Court of Bernalillo County: The trial court imposed two eight-year habitual offender enhancements on the Defendant's sentences but ordered them to run concurrently, resulting in an eleven-year total sentence instead of the nineteen years requested by the State (para 3).

Parties' Submissions

• Appellant (State): Argued that the trial court was required to impose the habitual offender enhancements consecutively because the Defendant's original felony sentences were ordered to be served consecutively. The State also contended that the Defendant's reasonable expectation of finality attached to the aggregate sentence rather than each individual sentence (paras 4, 7).
• Appellee (Defendant): Asserted that the trial court lacked jurisdiction to enhance the first felony sentence because the Defendant had fully served it, including the parole term, before the habitual offender hearing. The Defendant argued that double jeopardy principles precluded further punishment for the first felony (paras 4, 6).

Legal Issues

• Whether the trial court had jurisdiction to impose a habitual offender enhancement on a felony sentence after the Defendant had fully served that sentence, including parole.
• Whether the trial court erred in ordering the habitual offender enhancements to run concurrently rather than consecutively (para 4).

Disposition

• The Court of Appeals held that the trial court lacked jurisdiction to enhance the Defendant's sentence for the first felony after it had been fully served, including parole. The enhancement for the first felony was vacated (para 12).
• The Court did not address whether the trial court could properly order the enhancements to run concurrently, as the issue became moot (para 4).

Reasons

Per Vigil J. (Fry and Robinson JJ. concurring):

• The Court emphasized that a trial court's jurisdiction to enhance a sentence under the habitual offender statute expires once the Defendant has fully served the sentence, including any parole period. This principle is rooted in double jeopardy protections, which prevent further punishment for a crime once the sentence has been completed (paras 6-7).
• The Court rejected the State's argument that the Defendant's reasonable expectation of finality attached to the aggregate sentence rather than each individual sentence. The habitual offender statute explicitly applies to the "basic sentence" for each felony, not the aggregate sentence (para 8).
• The Court noted that double jeopardy concerns arise when additional punishment is imposed after a sentence has been fully served. The Defendant's expectation of finality in the first felony sentence was reasonable and attached once the sentence, including parole, was completed (paras 9-10).
• The Court dismissed the State's reliance on State v. Sandoval, clarifying that the timing of the filing of the habitual offender information does not extend the trial court's jurisdiction to enhance a sentence after it has been fully served (para 11).
• The Court concluded that the trial court lacked jurisdiction to enhance the Defendant's sentence for the first felony and remanded the case with instructions to vacate the eight-year enhancement for that offense (para 12).