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 child abuse resulting in the death of her boyfriend's 18-month-old child. The child sustained fatal head injuries while in the Defendant's care. The Defendant claimed the injuries occurred when the child fell from a lower bunk bed, but medical experts testified that the injuries were inconsistent with such a fall and were likely caused by significant force. The child died during surgery on the same day the injuries were discovered (paras 1, 3-14).
Procedural History
- District Court of Bernalillo County: The Defendant was convicted of child abuse resulting in death.
Parties' Submissions
- Defendant-Appellant: Argued that the trial court improperly communicated with a juror during deliberations, the evidence was insufficient to prove she caused the injuries, prosecutorial misconduct deprived her of a fair trial, improper witness opinions were allowed, jury instructions were erroneous, her sentence was improperly aggravated, and cumulative errors denied her due process (para 1).
- Plaintiff-Appellee: Contended that the evidence was sufficient to support the conviction and that the trial court's communication with the juror did not prejudice the Defendant (paras 1, 22-25).
Legal Issues
- Was there sufficient evidence to support the Defendant's conviction for child abuse resulting in death?
- Did the trial court's improper communication with a juror during deliberations warrant a reversal of the conviction?
Disposition
- The Defendant's conviction was reversed, and the case was remanded for a new trial (para 29).
Reasons
Per Pickard J. (Fry and Castillo JJ. concurring):
Sufficiency of Evidence: The court found that there was sufficient evidence to support the conviction. Expert testimony indicated that the injuries were inflicted shortly before the child displayed symptoms and while the child was in the Defendant's sole care. The jury's interpretation of the evidence was not inherently improbable, even though conflicting evidence was presented (paras 17-21).
Improper Communication with Juror: The trial court improperly communicated with a juror during deliberations about the jury's internal discussions. This communication concerned the subject matter of the case and created a presumption of prejudice. The State failed to rebut this presumption, as required by precedent. The court emphasized the sanctity of jury deliberations and the need to avoid any appearance of impropriety (paras 22-28).
Conclusion: The improper communication and the State's failure to rebut the presumption of prejudice necessitated the reversal of the conviction and a remand for a new trial (para 29).