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 driving under the influence (DWI) after consuming a "hot toddy" made by her sister, which contained alcohol, and over-the-counter cold medication. Unaware of the alcohol in the drink, the Defendant later drove her sister to the hospital, where she was stopped by police for speeding and failing to maintain her lane. The officer observed signs of intoxication, and after failing field sobriety tests, the Defendant was arrested for DWI (paras 2-4).

Procedural History

• Metropolitan court: Found the Defendant guilty of DWI under the "impaired to the slightest degree" standard, holding that DWI is a strict liability crime and involuntary intoxication is not a valid defense (para 5).
• District court: Affirmed the metropolitan court's conviction of the Defendant (para 5).

Parties' Submissions

• Defendant-Appellant: Argued that DWI under Subsection (A) is not a strict liability crime and that an involuntary intoxication defense should be available. Also contended there was insufficient evidence of being under the influence of over-the-counter cold medication (para 1).
• Plaintiff-Appellee (State of New Mexico): Maintained that DWI under Subsection (A) is a strict liability crime, making an involuntary intoxication defense inapplicable. Argued that there was sufficient evidence for the conviction.

Legal Issues

• Whether DWI, contrary to Subsection (A), is a strict liability crime.
• Whether an involuntary intoxication defense is available for DWI under Subsection (A), assuming it is a strict liability crime.
• Whether there was sufficient evidence that the Defendant was under the influence of over-the-counter cold medication (para 1).

Disposition

• The Court of Appeals affirmed the Defendant's conviction, holding that DWI under Subsection (A) is a strict liability crime and, consequently, an involuntary intoxication defense is not available (para 20).

Reasons

• Per JAMES J. WECHSLER, Judge (CELIA FOY CASTILLO, Chief Judge, and LINDA M. VANZI, Judge concurring):
  The Court determined that DWI under Subsection (A) is a strict liability offense, not requiring proof of intent, based on statutory interpretation and legislative intent to deter driving while intoxicated. This interpretation aligns with previous rulings that the per se standard of DWI is a strict liability crime. The Court also found that involuntary intoxication cannot serve as a defense to a strict liability crime because it is predicated on negating intent, which is irrelevant in strict liability offenses. The Court distinguished between the defenses of duress and involuntary intoxication, noting that duress does not negate intent but justifies the act under certain circumstances, making it applicable to strict liability crimes, unlike involuntary intoxication. Consequently, the Court did not address the sufficiency of evidence regarding the Defendant's intoxication from cold medication, as the resolution of the strict liability and involuntary intoxication issues rendered it moot (paras 6-19).