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 and the victim engaged in multiple physical altercations on January 12, 2000. That evening, the Defendant visited the victim's house with a friend. Another fight broke out when the victim returned home, which escalated outside. During the altercation, the victim sustained a fatal knife wound to the heart. The Defendant fled but was later detained. The Defendant was charged with first-degree murder and aggravated assault (paras 2-3).
Procedural History
- District Court of Bernalillo County: The Defendant was convicted of involuntary manslaughter after a jury trial. The trial court denied the Defendant's motions for a mistrial and a new trial, despite acknowledging potential prejudice from inadmissible testimony (paras 1, 4).
Parties' Submissions
- Defendant-Appellant: Argued that the trial court erred in denying a mistrial after the prosecution elicited testimony referencing the Defendant's prior incarceration, which violated a pretrial motion in limine and prejudiced the jury (paras 5, 9).
- Plaintiff-Appellee: Contended that the prosecutor did not intentionally elicit the improper testimony and that the curative instruction given by the trial court was sufficient to mitigate any prejudice (paras 7, 9).
Legal Issues
- Did the trial court err in denying the Defendant's motion for a mistrial after the prosecution elicited testimony referencing the Defendant's prior incarceration?
- Was there a reasonable probability that the improperly admitted evidence contributed to the jury's verdict?
Disposition
- The Court of Appeals reversed the Defendant's conviction and remanded the case for a new trial (para 12).
Reasons
Per Pickard J. (Robinson and Kennedy JJ. concurring):
The Court found that the prosecutor intentionally elicited testimony referencing the Defendant's prior incarceration, violating the motion in limine. The witness's hesitation and the prosecutor's repeated questioning demonstrated intent. The Court determined that the improper testimony created a reasonable probability of influencing the jury's verdict, given the conflicting evidence and the lack of overwhelming proof of guilt. The curative instruction was insufficient to mitigate the prejudice caused by the inadmissible evidence. Consequently, the trial court abused its discretion in denying the motion for a mistrial (paras 6-11).