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 convicted of criminal sexual contact of a minor (CSCM) based on allegations that the child victim was coerced into making false statements by the child’s mother, who was the Defendant’s former girlfriend. The mother had passed away before the trial, leaving her statements unexamined. The Defendant sought to introduce expert testimony to explain how children’s memories and statements can be influenced by external factors, but this evidence was excluded by the trial court (paras 1, 3-5).

Procedural History

• District Court of Bernalillo County: Convicted the Defendant of one count of CSCM and imposed a sentence of three years, aggravated by one-third (para 1).

Parties' Submissions

• Defendant-Appellant: Argued that the trial court erred in excluding expert testimony on the suggestibility and reliability of child witnesses, which was critical to the defense theory that the child was coerced into making false allegations. Also contended that the aggravated sentence violated the Sixth Amendment right to a jury trial (paras 1, 5, 15).
• Plaintiff-Appellee: Asserted that the expert testimony was irrelevant and would not assist the jury in determining the facts of the case. Further argued that the jury was capable of assessing the credibility of the child witness without expert assistance (paras 4-5, 8).

Legal Issues

• Did the exclusion of the Defendant’s expert witness violate the Defendant’s constitutional right to present a defense?
• Did the trial court’s exclusion of the expert testimony constitute prejudicial error?
• Did the trial court err in aggravating the Defendant’s sentence without a jury determination?

Disposition

• The Court of Appeals reversed the Defendant’s conviction and remanded the case for a new trial (para 1).
• The issue of the aggravated sentence was not addressed due to the reversal and remand (para 23).

Reasons

Per Roderick T. Kennedy J. (Bustamante and Robinson JJ. concurring):

• The trial court abused its discretion in excluding the expert testimony of Dr. Pardee, who was qualified to testify on the suggestibility and reliability of child witnesses. The testimony was relevant to the defense’s theory that the child was coerced into making false allegations (paras 9-11, 17).
• The exclusion of the expert testimony prejudiced the Defendant’s ability to present a complete defense. The testimony would have provided the jury with a framework to evaluate the child’s statements in the context of the defense’s theory (paras 13-14, 20).
• The trial court’s reasoning that the jury could assess the child’s credibility without expert assistance was flawed, as the expert’s testimony addressed issues beyond the common knowledge of jurors (paras 16-17).
• The exclusion of testimony from a police officer regarding the child’s mother’s prior conduct was upheld, as it was deemed speculative and irrelevant to the case (paras 21-22).
• The issue of the aggravated sentence was left to the trial court to address in the event of a new conviction (para 23).