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 stopped by police after being observed driving 40 mph in a 30 mph zone. Upon interaction, officers noted signs of alcohol consumption, including bloodshot eyes, slurred speech, and the smell of alcohol. The Defendant admitted to drinking earlier and performed field sobriety tests (FSTs), showing deficiencies. Blood alcohol tests revealed levels of .07 and .06, below the legal limit of .08. The Defendant argued that her performance on the FSTs was affected by external factors, such as cold and sloping conditions, and that her bloodshot eyes were due to contact lenses and fatigue.
Procedural History
- Metropolitan Court: Convicted the Defendant of driving under the influence of alcohol, impaired to the slightest degree, under NMSA 1978, Section 66-8-102(A).
- District Court: Affirmed the conviction.
Parties' Submissions
- Appellant (Defendant): Argued that the evidence was insufficient to support the conviction, citing alternative explanations for her bloodshot eyes, the impact of environmental conditions on her FST performance, and her blood alcohol levels being below the legal limit.
- Appellee (State): Asserted that the evidence, including the Defendant’s admission of drinking, physical signs of impairment, and FST performance, was sufficient to establish impairment to the slightest degree.
Legal Issues
- Was there sufficient evidence to support the Defendant’s conviction for driving under the influence of alcohol, impaired to the slightest degree?
Disposition
- The Court of Appeals affirmed the Defendant’s conviction.
Reasons
Per Vigil J. (Castillo and Kennedy JJ. concurring):
The Court held that substantial evidence supported the conviction. It emphasized that impairment to the slightest degree could be established through a combination of factors, including the Defendant’s admission of drinking, the odor of alcohol, bloodshot eyes, slurred speech, and deficiencies in FST performance. The Court noted that the blood alcohol levels below .08 did not preclude a finding of impairment under Section 66-8-102(A). The evidence, viewed in the light most favorable to the State, was sufficient for a rational trier of fact to find beyond a reasonable doubt that the Defendant was impaired to the slightest degree.