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 accused of committing a misdemeanor battery by throwing an orange at his brother's head during an argument. The incident occurred when the Defendant was angry at his brother for not cleaning up after his dog. The brother initially reported the incident to the police, but later changed his testimony, claiming that someone else threw the orange as a joke (paras 4-6).
Procedural History
- District Court, San Juan County: The district court revoked the Defendant's probation, finding that he violated a condition of his probation by committing a battery (para 2).
Parties' Submissions
- Defendant-Appellant: Argued that the evidence was inadequate to prove he violated a condition of his probation by committing a battery (para 2).
- Plaintiff-Appellee: Asserted that the evidence, including the Defendant's admission and the initial statement of the brother, was sufficient to establish a probation violation (paras 5, 10).
Legal Issues
- Was there sufficient evidence to prove that the Defendant violated a condition of his probation by committing a battery?
Disposition
- The Court of Appeals affirmed the district court's order revoking the Defendant's probation.
Reasons
Per Baca J. (Medina C.J. and Duffy J. concurring): The Court found that the evidence, viewed in the light most favorable to the State, supported the district court's conclusion that the Defendant committed a battery. The Defendant's admission and the initial statement of the brother were deemed credible, while the brother's later testimony was not. The Court noted that the Rules of Evidence do not strictly apply to probation violation hearings, allowing for the consideration of the brother's prior inconsistent statement as substantive evidence. The Court concluded that a reasonable mind could determine that the Defendant committed a battery, thus justifying the revocation of probation (paras 8-11).