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 entered the property of the complainant, with whom he had a prior romantic relationship, at her request to fix her truck. A confrontation ensued, during which the complainant fired a shotgun, and the Defendant disarmed her. The complainant alleged that the Defendant beat her with the gun, raped her, and held her against her will, while the Defendant claimed self-defense and denied the allegations of rape and false imprisonment (paras 3-5).
Procedural History
- District Court of Catron County: The Defendant was convicted of aggravated battery and criminal trespass but acquitted of criminal sexual penetration and false imprisonment (para 6).
Parties' Submissions
- Defendant-Appellant: Argued that the trial court erred in clarifying the self-defense jury instruction, admitting a prior inconsistent statement made after invoking the right to counsel, and rejecting a proposed plea agreement while allowing prosecution of charges that would have been dismissed under the agreement (paras 1, 9, 24, 36).
- Plaintiff-Appellee: Contended that the jury instructions were proper, the prior inconsistent statement was admissible for impeachment purposes, and the trial court acted within its discretion in rejecting the plea agreement and prosecuting the charges (paras 9, 24, 48).
Legal Issues
- Whether the trial court erred in its clarification of the self-defense jury instruction regarding a trespasser's right to stand their ground (para 1).
- Whether the trial court erred in admitting the Defendant's prior inconsistent statement made during a custodial interrogation after invoking the right to counsel (para 1).
- Whether the trial court abused its discretion in rejecting the proposed plea agreement and allowing prosecution of charges subject to dismissal under the agreement (para 1).
Disposition
- The conviction for aggravated battery was reversed, and the case was remanded for a new trial (para 55).
- The trial court's rulings on the admission of the prior inconsistent statement and rejection of the plea agreement were affirmed (para 55).
Reasons
Per Robinson J. (Bustamante and Fry JJ. concurring):
Self-Defense Jury Instruction: The trial court's clarification of the self-defense instruction was erroneous. The instruction failed to address the interplay between trespass and self-defense adequately, did not impose the State's burden to prove the Defendant did not act in self-defense, and could have been interpreted as requiring the Defendant to retreat even in the face of unlawful deadly force. The case was remanded for a new trial with proper jury instructions (paras 7-20).
Admission of Prior Inconsistent Statement: The Defendant's statement made after invoking the right to counsel was admissible for impeachment purposes. The court complied with Rule 11-613(B) by allowing the Defendant an opportunity to cross-examine the officer and offer surrebuttal. The statement was not used as substantive evidence, and no foundational error occurred (paras 21-35).
Rejection of Plea Agreement: The trial court acted within its discretion in rejecting the plea agreement. The court considered factors such as the disparity between the charges and the proposed plea, the Defendant's lack of remorse, and the victim's testimony. The State's decision to prosecute the charges was supported by sufficient evidence and did not constitute misconduct (paras 36-54).