This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
Two petitioners, one convicted of multiple felonies and the other serving a life sentence for murder, filed habeas corpus petitions challenging the legality of their sentences. The first petitioner argued that his sentence was unlawfully enhanced without prior notice, while the second petitioner contested the forfeiture of good time credits following his escape and subsequent incarceration in another state (paras 3-4, 16-17).
Procedural History
- District Court, Santa Fe County: Both habeas corpus petitions were dismissed after significant delays in processing. The first petition was summarily dismissed, while the second was dismissed for inactivity (paras 1, 15, 22).
Parties' Submissions
- Petitioners: Argued that the delays in processing their habeas corpus petitions entitled them to default judgments. The first petitioner also claimed his sentence was illegally enhanced without notice, violating due process. The second petitioner argued that the forfeiture of good time credits for his escape was unlawful and violated his due process rights (paras 5, 17-18, 28, 47).
- Respondents: Contended that default judgments are not authorized in habeas corpus proceedings and that the first petitioner’s sentence enhancement was lawful under the statute. They also argued that the second petitioner was not entitled to good time credits for the period he was incarcerated in another state (paras 28-29, 48).
Legal Issues
- Whether the delays in processing the habeas corpus petitions entitled the petitioners to default judgments (para 28).
- Whether the first petitioner’s sentence enhancement without prior notice violated due process (para 41).
- Whether the second petitioner was unlawfully deprived of good time credits and denied due process (para 47).
Disposition
- The dismissal of the first petitioner’s habeas corpus petition was reversed, and the case was remanded for resentencing (para 46).
- The dismissal of the second petitioner’s habeas corpus petition was affirmed (para 50).
Reasons
Per Montgomery J. (Ransom and Franchini JJ. concurring):
Default Judgments: The Court acknowledged that default judgments could be available in habeas corpus proceedings as a sanction for extreme delays but found that the delays in these cases did not justify such a remedy. The State’s conduct, while not exemplary, did not amount to stubborn resistance or recalcitrance (paras 2, 34-39).
First Petitioner (Caristo): The Court held that due process requires notice of the State’s intent to seek sentence enhancement and the specific aggravating factors to be relied upon. The lack of such notice rendered the sentence enhancement unlawful. The case was remanded for resentencing to ensure compliance with due process (paras 41-46).
Second Petitioner (Kinslow): The Court found that the Department of Corrections had not unlawfully forfeited good time credits but had merely suspended the petitioner’s sentence during his escape and subsequent incarceration in another state. The petitioner was not entitled to good time credits for the period he was not serving his New Mexico sentence. The dismissal of his petition was affirmed (paras 48-50).