AI Generated Opinion Summaries

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Facts

The Driver was arrested for DWI in February 1997 after appearing intoxicated and recording a breath test result of 0.20. Following the arrest, the Driver was served with a notice of license revocation under the Implied Consent Act. Despite having a prior DWI conviction, the Driver entered into a guilty plea agreement in district court, where the offense was treated as a first offense "for all lawful purposes" (paras 2-3).

Procedural History

• District Court, May 1997: The district court reversed the Motor Vehicle Division's decision to revoke the Driver's license, relying on the precedent set in Collyer v. State Taxation & Revenue Dep't, which held that a district court judgment treating a DWI conviction as a first offense binds the Division to do the same (paras 1, 4).

Parties' Submissions

• Appellant (Motor Vehicle Division): Argued that the district court's judgment treating the DWI conviction as a first offense "for all lawful purposes" does not affect the Division's authority to revoke licenses under the Implied Consent Act. The Division maintained that the revocation was lawful because the Driver had a prior license revocation under the Act (paras 1, 3, 8).
• Appellee (Driver): Contended that the district court's judgment in the DWI proceeding, which treated the offense as a first offense, precluded the Division from revoking the license under the Implied Consent Act. The Driver also argued that the Division was bound by the plea agreement and the district court's judgment (paras 3-4, 9).

Legal Issues

• Does a district court judgment treating a DWI conviction as a first offense "for all lawful purposes" preclude the Motor Vehicle Division from revoking a driver's license under the Implied Consent Act?
• Is the precedent set in Collyer v. State Taxation & Revenue Dep't applicable to license revocations under the Implied Consent Act?

Disposition

• The Court of Appeals reversed the district court's decision and reinstated the Motor Vehicle Division's order to revoke the Driver's license for one year (para 11).

Reasons

Per Apodaca J. (Pickard and Armijo JJ. concurring):

• The Court distinguished the present case from Collyer v. State Taxation & Revenue Dep't. In Collyer, the license revocation was based on a different statutory provision, NMSA 1978, § 66-5-29(A)(3), which requires defining a driver as a "subsequent offender." In contrast, the Implied Consent Act, under Section 66-8-111(C)(3), mandates a one-year revocation if the driver has a prior license revocation under the Act, regardless of prior DWI convictions (paras 8-9).
• The Court held that the district court's judgment treating the DWI conviction as a first offense did not preclude the Division from revoking the license under the Implied Consent Act. The administrative hearing focused on whether the Driver had a prior revocation under the Act, which was a separate issue from the district court's determination of the DWI offense status (paras 9-10).
• The Court rejected the Driver's collateral estoppel argument, finding that the issues decided in the district court and the administrative hearing were not the same. The district court's judgment addressed the DWI offense, while the administrative hearing determined the applicability of the Implied Consent Act based on prior revocations (para 10).
• The Court concluded that the hearing officer's interpretation of the Implied Consent Act was reasonable and lawful, and the district court erred in reversing the revocation order (para 11).