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, Ryan Begay, was involved in an incident on June 26, 2013, where he, along with his girlfriend and her sister, went to an apartment complex in Albuquerque to purchase heroin. After an argument with Sabra’s cousin, Trey Gomez, the Defendant fired several gunshots in Trey's direction as they drove away, believing they were being shot at. One of the bullets struck twenty-month-old J.A. in her leg. The Defendant later disposed of the gun in the Rio Grande River (paras 3-4).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the evidence was insufficient to support the child abuse convictions, claimed a denial of due process, raised double jeopardy concerns, contested the verdicts as inconsistent, challenged the striking of a juror for cause, and claimed ineffective assistance of counsel (para 1).
• Plaintiff-Appellee: Contended that the convictions should be upheld, arguing against the Defendant's claims on the grounds of sufficiency of evidence, due process, double jeopardy, inconsistent verdicts, juror excusal, and ineffective assistance of counsel claims.

Legal Issues

• Whether there was sufficient evidence to support the Defendant's child abuse convictions.
• Whether the Defendant's due process rights were violated.
• Whether the convictions violated the principle of double jeopardy.
• Whether the verdicts were inconsistent.
• Whether the excusal of a juror for cause was erroneous.
• Whether the Defendant received ineffective assistance of counsel (paras 1-2, 22, 23, 49, 56).

Disposition

• The court concluded that the Defendant’s convictions for two counts of child abuse (recklessly caused, no death or great bodily harm) violated double jeopardy principles and remanded the case, directing the district court to vacate one of these two counts. The court otherwise affirmed the Defendant's convictions (para 2).

Reasons

• Sufficiency of Evidence: The court found substantial evidence supporting the Defendant's convictions for child abuse, including testimony that the children were in the parking lot near the Defendant when he fired the shots and that J.A. suffered great bodily harm as a result (paras 5-21).
  Due Process: The court rejected the Defendant's due process claim, finding that a reasonable jury could conclude the Defendant was aware of the children's presence and recklessly disregarded their safety (para 22).
  Double Jeopardy: The court held that the convictions for two counts of child abuse (recklessly caused, no death or great bodily harm) violated double jeopardy, but the separate convictions for child abuse (recklessly caused, great bodily harm) and shooting from a motor vehicle did not violate double jeopardy principles (paras 23-37).
  Inconsistent Verdicts: The court declined to entertain the Defendant's argument regarding inconsistent verdicts, adhering to the principle of reviewing verdicts of conviction without concerning itself with acquittals or alleged inconsistencies (paras 49-52).
  Excusal of a Prospective Juror for Cause: The court found no abuse of discretion in the excusal of a prospective juror who stated his religious beliefs would prevent him from making a decision in the case (paras 53-55).
  Ineffective Assistance of Counsel: The court concluded that the Defendant did not establish a prima facie case of ineffective assistance of counsel regarding the rejection of a plea offer based on mistaken advice about potential sentencing (paras 56-60).