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 stopped by law enforcement and exhibited signs of alcohol impairment, including smelling strongly of alcohol, having bloodshot and watery eyes, slurred speech, and poor performance on field sobriety tests. The Defendant admitted to consuming two drinks but argued that his medical conditions, including arthritis in his ankle and a missing bone in his ear, affected his ability to perform the sobriety tests. The officers testified that they were not informed of these medical conditions and observed no physical impairments that would explain the Defendant's poor performance.
Procedural History
- Metropolitan Court: The Defendant was convicted of driving while intoxicated (DWI) under NMSA 1978, Section 66-8-102(A) (2007) following a bench trial.
- District Court of Bernalillo County: The conviction was affirmed on appeal.
Parties' Submissions
- Defendant-Appellant: Argued that the evidence was insufficient to support the conviction, citing his medical impairments as the reason for his poor performance on the field sobriety tests. He also claimed that the officers failed to consider these impairments and that his testimony contradicted the officers' accounts.
- State-Appellee: Asserted that the evidence, including the Defendant's physical signs of impairment, his admission of alcohol consumption, and his poor performance on sobriety tests, was sufficient to support the conviction. The State argued that the trial court was entitled to reject the Defendant's testimony and rely on the officers' observations.
Legal Issues
- Was there sufficient evidence to support the Defendant's conviction for driving while intoxicated under NMSA 1978, Section 66-8-102(A) (2007)?
Disposition
- The Court of Appeals of New Mexico affirmed the Defendant's conviction for DWI.
Reasons
Per Wechsler J. (Vigil and Robles JJ. concurring):
The Court held that the evidence presented at trial was sufficient to support the Defendant's conviction. The officers' testimony regarding the Defendant's physical signs of impairment, his admission of alcohol consumption, and his poor performance on field sobriety tests provided substantial evidence of impairment to the slightest degree, as required under Section 66-8-102(A).
The Court emphasized that it does not reweigh evidence or assess witness credibility on appeal. It noted that the trial court was free to reject the Defendant's testimony about his medical impairments and accept the officers' accounts. The Court also found that the trial court reasonably inferred that the Defendant's poor performance on the sobriety tests was due to alcohol consumption, as no evidence was presented to show how the medical conditions would have affected his performance.
The Court concluded that the trial court's decision was supported by substantial evidence and affirmed the conviction.