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 case involves the Defendant, Lauren Owelicio, who was convicted of aggravated driving under the influence (DWI) after a bench trial. The conviction stemmed from an incident where police responded to a reported accident and found a vehicle with two flat front tires and the Defendant in the passenger seat. The Defendant initially did not admit to driving but later confessed multiple times to having been the driver after consuming three drinks at a nightclub. This confession was made despite another individual, Aaron Atcitty, being present and initially seen changing a tire but denying he was driving. The Defendant later recanted her confession at trial, claiming she only admitted to driving to protect Atcitty's job (paras 2-6, 9-11).

Procedural History

• Appeal from the District Court of Bernalillo County: Affirmed the metropolitan court's conviction of the Defendant for aggravated DWI.
• Certiorari Granted, September 9, 2011, No. 33,143. Certiorari Quashed October 12, 2012, No. 33,143.

Parties' Submissions

• Defendant-Appellant: Argued that her uncorroborated extrajudicial statement admitting to driving was insufficient to support her conviction for aggravated DWI. Contended that there was insufficient evidence to prove she was driving the vehicle, as her admission was the only evidence supporting that finding (para 13).
• Plaintiff-Appellee (State of New Mexico): Contended that the modified trustworthiness rule does not apply to the Defendant’s admission to driving because her identity as the driver is not part of the corpus delicti of the offense of DWI. Argued that there was independent evidence that the crime of DWI was committed by someone, making the Defendant's admission unnecessary for establishing the corpus delicti of DWI (para 14).

Legal Issues

• Whether the Defendant's uncorroborated extrajudicial statement admitting to driving is sufficient to support her conviction for aggravated DWI.
• Whether the modified trustworthiness rule requires corroboration of the Defendant's admission to driving to establish the corpus delicti of the offense of DWI.

Disposition

• The Court of Appeals of New Mexico affirmed the district court judgment affirming the Defendant's conviction for aggravated DWI (para 35).

Reasons

• Per JAMES J. WECHSLER, with concurrence from MICHAEL D. BUSTAMANTE and CYNTHIA A. FRY, the court held that evidence someone was driving while intoxicated established the corpus delicti of the crime. It was determined that there was sufficient evidence to support the Defendant's conviction, including corroborating evidence of the Defendant's admission that she was driving. The court applied a de novo standard of review and concluded that the identity of the perpetrator is not material to establishing the corpus delicti of DWI. The court disagreed with the Defendant's contention that her admission was untrustworthy based on the corpus delicti or trustworthiness rule, noting that the traditional corpus delicti rule has been abandoned in New Mexico for a modified version of the trustworthiness rule. The court found that there was independent evidence of DWI being committed and sufficient corroborating evidence to establish the trustworthiness of the Defendant's admission. The court also addressed the sufficiency of the evidence, viewing it in the light most favorable to the verdict and finding it sufficient to conclude that the Defendant was driving the vehicle in an intoxicated state (paras 14-34).