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, Kendra Frazier, was charged with three misdemeanors, including driving while intoxicated (DWI), and one fourth-degree felony for receiving stolen property. After her arrest, the felony and two misdemeanor charges were dismissed, leaving only the DWI charge. The Defendant moved to dismiss the DWI charge, arguing that the case did not proceed to resolution within the 182-day limit as prescribed by Rule 6-506 NMRA. The magistrate court denied the motion, and the Defendant entered a conditional plea of no contest to the DWI charge, reserving the right to appeal the decision on the 182-day rule violation (paras 2-3).

Procedural History

• District Court of San Juan County: Affirmed the denial of the Defendant's motion to dismiss her case for violating Rule 6-506 NMRA.

Parties' Submissions

• Defendant-Appellant: Argued that the 182-day rule was violated because the case did not proceed to resolution within the prescribed time limit, asserting that her first appearance should be considered as an implied waiver of arraignment, which should have triggered the rule (para 7).
• Plaintiff-Appellee: The State's arguments are not explicitly detailed in the provided text, but it can be inferred that the State argued against the Defendant's interpretation of Rule 6-506 and the timing of the arraignment.

Legal Issues

• Whether the Defendant’s right to the resolution of her case within 182 days, as prescribed by Rule 6-506, was violated.

Disposition

• The New Mexico Court of Appeals affirmed the district court's decision, holding that the 182-day rule was not violated in the Defendant's case (para 1).

Reasons

• Per Medina, J. (Vanzi and Zamora, JJ., concurring): The Court found that the magistrate court did not have trial jurisdiction over the misdemeanor charges at the Defendant's first appearance due to the accompanying felony charge. Therefore, the 182-day rule was not triggered at the first appearance. The Court concluded that the magistrate court obtained trial jurisdiction over the Defendant’s DWI charge when the State entered its nolle prosequi of the felony and two other misdemeanor charges, effectively entering a not guilty plea on the Defendant's behalf and constructively arraigning her on the DWI charge. The Court determined that the trial should have commenced within 182 days of May 19, 2016, and found that the case was timely resolved within the prescribed period, affirming the district court's order (paras 4-20).