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 charged with offenses related to driving under the influence. The case involved the administration of a Horizontal Gaze Nystagmus (HGN) test and the use of an IR-8000 breathalyzer to determine the Defendant's level of intoxication. The State failed to file a written response to the Defendant's motions to suppress evidence from these tests within the required timeframe under Rule 5-120(E) NMRA.

Procedural History

• Magistrate Court: The Defendant was convicted of charges related to driving under the influence.
• District Court, October 27, 2009: The court suppressed the results of the HGN test and the IR-8000 breathalyzer as a sanction for the State's failure to file a written response to the Defendant's motions to suppress within the required timeframe.

Parties' Submissions

• Appellant (State): Argued that the suppression of evidence was unwarranted because the Defendant failed to demonstrate any prejudice resulting from the State's failure to file a written response to the motions to suppress.
• Appellee (Defendant): Contended that the State's failure to file a written response to the motions to suppress and its failure to disclose a witness list caused prejudice, justifying the suppression of the HGN and IR-8000 results.

Legal Issues

• Was the suppression of the HGN test and IR-8000 results as a sanction for the State's failure to file a written response to the Defendant's motions to suppress justified under Rule 5-120(E) NMRA?

Disposition

• The Court of Appeals reversed the district court's order suppressing the HGN test and IR-8000 results.

Reasons

Per Bustamante J. (Sutin and Garcia JJ. concurring):

The Court of Appeals reviewed the district court's decision for an abuse of discretion. It held that sanctions, such as the suppression of evidence, require a showing of prejudice resulting from the violation. The Defendant failed to demonstrate any prejudice caused by the State's failure to file a written response to the motions to suppress. The suppression order was based solely on the procedural violation under Rule 5-120(E) NMRA, which is insufficient without evidence of prejudice. The Court also noted that the district court had addressed the State's failure to disclose a witness list separately and did not base the suppression order on that issue. Consequently, the suppression of the HGN and IR-8000 results was unwarranted.