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 first-degree murder, conspiracy to commit first-degree murder, kidnapping, aggravated burglary, and tampering with evidence. The case involved the murder of the Defendant's elderly aunt, who was found asphyxiated in her home. The Defendant's ex-girlfriend testified that the Defendant killed his aunt to obtain money to pay off a drug debt (paras 1, 19-24).
Procedural History
- District Court, November 9, 2022: The Defendant was convicted of first-degree murder and other related charges (para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the district court abused its discretion by denying motions for mistrial due to a juror's illness, that the conspiracy conviction was not supported by sufficient evidence, and that counsel was ineffective due to late appointment (para 1).
- Plaintiff-Appellee: Contended that the district court acted within its discretion, the evidence was sufficient to support the conspiracy conviction, and the Defendant received effective legal representation.
Legal Issues
- Did the district court abuse its discretion in denying the Defendant’s motions for mistrial when a juror became ill during deliberations?
- Is the Defendant’s conviction for conspiracy to commit first-degree murder supported by sufficient evidence?
- Was the Defendant’s counsel ineffective due to being appointed approximately three months prior to trial?
Disposition
- The Supreme Court of New Mexico affirmed the Defendant’s conviction and sentence (para 2).
Reasons
Per Thomson, Chief Justice (Vigil and Vargas JJ. concurring):
The district court did not abuse its discretion in denying the Defendant's motions for mistrial. The court explored reasonable alternatives to a mistrial, and the recess in deliberations did not prejudice the Defendant. The evidence was sufficient to support the conspiracy conviction, as the jury could reasonably infer an agreement to commit murder based on the Defendant's and his ex-girlfriend's actions and testimony. The Defendant failed to demonstrate ineffective assistance of counsel, as the defense was adequately prepared and executed despite the late appointment of counsel (paras 3-42).
Bacon, Justice, dissenting in part:
Justice Bacon dissented on the sufficiency of the evidence for the conspiracy conviction. The evidence was circumstantial and did not reasonably support the inference that the Defendant and his ex-girlfriend conspired to commit murder. The evidence presented was equally consistent with other non-murderous criminal objectives, and the jury's conclusion required speculation (paras 45-60).