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 indicted for distribution of an imitation controlled substance and possession of a controlled substance. He entered a plea agreement, pleading guilty to the possession charge in exchange for the dismissal of the distribution charge and a sentence of probation. The district court deferred sentencing, referred the Defendant to a drug court program, and later granted a conditional discharge after successful completion of the program. The court dismissed the charges with prejudice but imposed a $75 crime lab fee, which the Defendant contested, arguing that a conditional discharge does not constitute a conviction (paras 2-3).

Procedural History

• District Court, October 30, 2000: The Defendant entered a plea agreement, pleading guilty to possession of a controlled substance. The court deferred sentencing and referred the Defendant to a drug court program (para 2).
• District Court, October 2001: After the Defendant successfully completed the drug court program, the court granted a conditional discharge, dismissed the charges with prejudice, and later imposed a $75 crime lab fee (paras 2-3).

Parties' Submissions

• Defendant-Appellant: Argued that a conditional discharge is not a conviction under the crime lab fee statute, and therefore, the imposition of the $75 fee was unauthorized. He also contended that the plea agreement did not unambiguously require him to pay the fee and that the fee was an illegal sentence (paras 3, 11-14).
• State-Appellee: Asserted that the guilty plea constituted a conviction, making the fee permissible under the statute. Alternatively, the State argued that the Defendant agreed to pay the fee as part of the plea agreement and waived his right to appeal any sentence imposed under its terms (paras 4, 11-12).

Legal Issues

• Whether a conditional discharge constitutes a conviction for the purposes of imposing a crime lab fee under NMSA 1978, Section 31-12-8 (1988) (para 5).
• Whether the plea agreement unambiguously required the Defendant to pay the $75 crime lab fee (para 11).

Disposition

• The Court of Appeals reversed the district court's decision to impose the $75 crime lab fee and remanded the case for entry of an amended order consistent with its opinion (para 20).

Reasons

Per Bustamante J. (Castillo and Robinson JJ. concurring):

• The Court held that under the plain language of the conditional discharge statute, a conditional discharge is not a conviction. The statute explicitly states that a discharge and dismissal under its terms shall not be deemed a conviction for any purpose, including the imposition of penalties such as the crime lab fee (paras 6-8).
• The Court emphasized that the crime lab fee statute requires a conviction as a prerequisite for imposing the fee. Since the Defendant successfully completed probation and the charges were dismissed, there was no conviction, and the fee was unauthorized (paras 6-10).
• Regarding the plea agreement, the Court found that the terms were ambiguous. The $75 fee was listed under the penalties section, which could reasonably be interpreted as a notification of potential consequences rather than a binding term. The Court construed the ambiguity in favor of the Defendant, finding that he did not unambiguously agree to pay the fee (paras 13-17).
• The Court rejected the State's argument that the Defendant waived his right to appeal by agreeing to the plea terms, noting that there was no evidence the Defendant invited the error or agreed to an illegal sentence (paras 18-19).