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Decision Information

Citations - New Mexico Appellate Reports
State v. Rodriguez - cited by 0 documents

Decision Content

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, involved in a series of criminal activities known as "car and house mobbing" with a group, engaged in burglary and theft, leading to the death of Steven Gerecke. The group's activities included breaking into homes and stealing cars while intoxicated. The Defendant, identified as a key participant, was apprehended and charged with multiple crimes, including aggravated burglary and conspiracy, following his involvement in these activities (paras 2, 4-5, 8-10).

Procedural History

  • State v. Rodriguez (Rodriguez I), A-1-CA-37324, mem. op. (N.M. Ct. App. Nov. 27, 2019) (nonprecedential): The Court dismissed the appeal, holding the Defendant waived his right to appeal under his plea agreement (para 3).
  • State v. Rodriguez (Rodriguez II), 2023-NMSC-004, 528 P.3d 614: The Supreme Court reversed Rodriguez I, holding a juvenile’s guilty plea cannot waive the right to an amenability determination or the right to appeal such a determination, and remanded for review of the district court’s nonamenability determination (para 1).

Parties' Submissions

  • Defendant-Appellant: Argued that the district court abused its discretion by finding him not amenable to treatment in available facilities, despite unanimous testimony to his amenability (para 20).
  • Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

  • Whether the district court abused its discretion by finding the Defendant not amenable to treatment or rehabilitation in available facilities, despite evidence suggesting amenability (para 20).

Disposition

  • The Court of Appeals affirmed the district court’s determination that the Defendant was not amenable to treatment or rehabilitation under the Delinquency Act, thereby upholding the imposition of an adult sentence (para 1).

Reasons

  • Per MEDINA, J., with ATTREP, C.J., and HANISEE, J., concurring:
    The Court reviewed the district court's amenability determination under an abuse of discretion standard, considering evidence in the light most favorable to the decision (para 21).
    The district court made extensive findings on the seriousness of the offense, the manner of commission, use of a firearm, offenses against persons or property, the Defendant's maturity, criminal history, prospects for public protection and rehabilitation, and other relevant factors. It concluded that the Defendant's lengthy criminal history, high risk of recidivism, and failure to consistently engage in counseling demonstrated a lack of amenability to treatment as a juvenile (paras 23-31).
    The Court found no abuse of discretion in the district court's decision, noting that the district court considered all necessary factors and evidence, including expert opinions and the Defendant's behavior while detained. The decision was not against the logic and effect of the facts and circumstances of the case or a misunderstanding of the law (para 33).
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