This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
In November 2014, a drug dealer and his accomplice were shot in the back of the head while sitting in a car, leading to their deaths. The Defendant was charged with two counts of felony murder for these killings, which occurred during an attempted robbery. The Defendant admitted to being present at an earlier meeting with the victims but denied involvement in the murders, claiming he was asleep at the time (paras 3-8).
Procedural History
- District Court, Date: The Defendant was convicted of two counts of felony murder and sentenced to two consecutive life terms. The Defendant's motion for a new trial based on newly discovered evidence was denied (paras 1, 11).
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred in admitting certain evidentiary items, including lay opinion testimony, out-of-court statements by an unavailable witness, and text messages. Also challenged the denial of a motion for a new trial based on newly discovered evidence (paras 1-2, 11).
- Plaintiff-Appellee: Contended that the evidence was properly admitted and that any errors were harmless. Argued that the district court correctly denied the motion for a new trial (paras 1-2, 11).
Legal Issues
- Whether the district court abused its discretion by admitting lay opinion testimony that surveillance videos depicted the same two people.
- Whether the district court erred in admitting out-of-court statements from a co-defendant as statements against penal interest.
- Whether the district court erred in admitting text messages between the co-defendant and one of the victims.
- Whether the district court erred in denying the Defendant's motion for a new trial based on newly discovered evidence.
Disposition
- The Supreme Court of New Mexico affirmed the Defendant's convictions (para 53).
Reasons
Per Bacon J. (Thomson C.J., Vigil, Vargas, and Zamora JJ. concurring):
The Court found that the district court did not abuse its discretion in admitting the lay opinion testimony, as the detective's extensive review of the surveillance videos provided a basis for her opinion that was helpful to the jury (paras 14-22). The Court also held that the out-of-court statements by the co-defendant were admissible as statements against penal interest, as they exposed the co-defendant to significant criminal liability and were corroborated by other evidence (paras 23-39). The text messages were not hearsay because they were not used to prove the truth of the matter asserted, and any error in their admission was harmless (paras 45-50). Finally, the Court concluded that the district court did not manifestly abuse its discretion in denying the motion for a new trial, as the newly discovered evidence was merely contradictory (paras 51-52).