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 was convicted for trafficking methamphetamine. He sought to establish an entrapment defense but argued that his ability to testify was hindered by the court's decision to allow evidence of his involvement in a prior uncharged drug transaction for impeachment purposes if he chose to testify (para 2).

Procedural History

• Appeal from the District Court of Valencia County, Cindy M. Mercer, District Judge, January 24, 2017: Conviction for trafficking methamphetamine affirmed.

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by denying his motion in limine to exclude evidence of a prior uncharged drug transaction, which prevented him from testifying and establishing his defense of entrapment (para 2). Also contended that the district court erred in refusing to order the State to reveal the identity of a confidential informant, which was necessary for a fair determination of guilt or innocence (para 5).
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the district court erred in denying the Defendant's motion in limine to exclude evidence of his involvement in a prior uncharged drug transaction (para 2).
• Whether the district court erred in refusing to order the State to reveal the identity of a confidential informant (para 5).

Disposition

• The Court of Appeals affirmed the Defendant's conviction for trafficking methamphetamine (para 9).

Reasons

• Per LINDA M. VANZI, Chief Judge (MICHAEL E. VIGIL, Chief Judge, and TIMOTHY L. GARCIA, Judge concurring):
  The Court found no abuse of discretion in the denial of Defendant’s motion in limine. It held that evidence of a prior instance of methamphetamine trafficking could be relevant and admissible under Rule 11-404(B) NMRA depending on the substance of Defendant’s testimony, especially in establishing the defense of entrapment (para 3).
  The Court rejected the Defendant's assertion of error regarding the potential for impeachment if he testified, noting that he cited no authority to support his argument that a criminal defendant is not subject to impeachment (para 4).
  Regarding the refusal to disclose the identity of a confidential informant, the Court found that the district court did not abuse its discretion. It conducted an in camera review and determined there was no information relevant or helpful to the Defendant's case. The Court also noted that the Defendant did not specifically explain how the informant’s identity was necessary to establish his defense of entrapment, and the informant was not a witness to the drug transaction for which he was charged (paras 5-8).