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 at a DWI sobriety checkpoint where he admitted to consuming alcohol earlier that day. Officers noted signs of intoxication, including the smell of alcohol, bloodshot eyes, slurred speech, and compromised balance. The Defendant performed field sobriety tests poorly and refused a breath test, citing medical conditions and anxiety (paras 2-8).
Procedural History
- Metropolitan Court of Bernalillo County: The Defendant was convicted of aggravated DWI (para 9).
Parties' Submissions
- Defendant-Appellant: Argued that the metropolitan court committed structural error by not affording him the presumption of innocence and that the evidence was insufficient to convict him due to his medical conditions affecting his performance on sobriety tests (paras 1, 10-11, 15).
- Plaintiff-Appellee: Contended that the court did not commit structural or fundamental error and that the evidence was sufficient to support the conviction, as the Defendant's interest in the trial outcome was a valid consideration for credibility (paras 11-12).
Legal Issues
- Did the metropolitan court commit structural error by not affording the Defendant the presumption of innocence?
- Was the evidence sufficient to convict the Defendant of aggravated DWI?
Disposition
- The New Mexico Court of Appeals affirmed the conviction (para 20).
Reasons
Per Bogardus J. (Attrep and Yohalem JJ. concurring): The court found no structural or fundamental error, as the metropolitan court's comments on the Defendant's credibility were appropriate and did not deprive him of the presumption of innocence. The court also held that sufficient evidence supported the conviction, including the Defendant's admission of alcohol consumption, physical signs of intoxication, and refusal to submit to a breath test. The Defendant's arguments regarding his medical conditions were not adequately supported by legal authority or evidence (paras 13-19).