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 initially claimed to have shot her former boyfriend in self-defense during a violent altercation at a residence. However, she later admitted that another individual, with whom she was staying, had committed the shooting. The Defendant maintained that the shooting was in self-defense due to the victim's violent behavior and threats. The Defendant was charged with making a false report, harboring a felon, and conspiracy to harbor a felon (paras 2-3).
Procedural History
- District Court of Bernalillo County: The Defendant was convicted of making a false report and conspiracy to harbor a felon but acquitted of harboring a felon (para 3).
Parties' Submissions
- Defendant-Appellant: Argued that her false confession did not fall within the scope of the false reporting statute, as it did not falsely accuse another person of a crime. She also contended that the jury instructions on conspiracy were flawed, as they failed to include the elements of the alleged predicate felony, and that the trial court erred in denying her motion to set aside the verdict or grant a new trial (paras 4, 11, 18).
- Plaintiff-Appellee: Asserted that the false reporting statute should be interpreted broadly to include any false statements that divert law enforcement from the actual perpetrator. The Plaintiff also argued that the jury instructions were sufficient and that the evidence supported the conspiracy conviction (paras 5, 14, 19).
Legal Issues
- Whether the Defendant’s false confession fell within the scope of the false reporting statute (para 4).
- Whether the trial court erred in failing to instruct the jury on the elements of the predicate felony in the conspiracy charge (para 11).
- Whether the trial court erred in denying the Defendant’s motion to set aside the verdict or grant a new trial (para 18).
Disposition
- The conviction for making a false report was reversed (para 9).
- The conviction for conspiracy to harbor a felon was reversed, and the case was remanded for a new trial on that charge (para 21).
Reasons
Per Donnelly J. (Minzner and Chavez JJ. concurring):
False Reporting Statute: The court held that the false reporting statute criminalizes false accusations against another person, not false confessions that shift blame onto oneself. The statute’s plain language and legislative intent do not support the broader interpretation advanced by the State. As the Defendant’s conduct did not fall within the statute’s scope, the conviction for making a false report was reversed (paras 4-9).
Conspiracy to Harbor a Felon: The court found that the jury instructions were deficient because they failed to include the elements of the predicate felony (murder) alleged to have been the object of the conspiracy. The Defendant was entitled to have the jury instructed on her theory that the shooting was justifiable as self-defense. The omission of these instructions required reversal of the conspiracy conviction and a remand for a new trial (paras 11-17).
Motion to Set Aside Verdict: The court rejected the Defendant’s argument that her acquittal on the harboring charge precluded a conviction for conspiracy. The crimes involve different elements, and the evidence was sufficient to support the conspiracy conviction. However, due to the instructional error, the conspiracy conviction was reversed (paras 18-19).