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

• Petitioner Dana McGarrh pleaded guilty to three misdemeanor driving while intoxicated (DWI) charges between 1989 and 2001 in San Juan County municipal courts. In 2003, he pleaded guilty to a fourth DWI, resulting in a fourth-degree felony conviction. After completing his sentence in March 2006, McGarrh filed a Rule 5-803 petition in 2020 seeking to invalidate all four pleas on the grounds that the judges did not articulate what the State must prove for conviction (para 2).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioner-Appellant: Argued that the district court erred in summarily dismissing his Rule 5-803 petition. He contended that the judges in each plea hearing failed to articulate on the record the nature of the charges and what the State must prove, which was required by clear rule requirements (para 2).
• Respondent-Appellee: The State's arguments are not explicitly detailed in the decision.

Legal Issues

• Whether the district court had jurisdiction under Rule 5-803 to review misdemeanor pleas entered in municipal courts within the Eleventh Judicial District Court (para 6).
• Whether the district court abused its discretion in determining the petition to be untimely (para 8).
• Whether the four pleas were knowing and voluntary under New Mexico law (para 12).

Disposition

• The district court’s jurisdictional ruling was reversed, but the dismissal of the Petition was otherwise affirmed (para 20).

Reasons

• The Court of Appeals found that the district court had jurisdiction to review the misdemeanor pleas because they were entered in municipal courts located within the Eleventh Judicial District Court, thus reversing the district court's jurisdictional ruling (paras 6-7). However, the Court of Appeals agreed with the district court that the petition was untimely, as it was filed approximately fifteen years after the completion of McGarrh's sentence without demonstrating good cause, excusable neglect, or extraordinary circumstances for the delay (paras 8-11). Regarding the validity of the four pleas, the Court of Appeals concluded that the record of the fourth plea colloquy demonstrated that the plea was knowing and voluntary. For the misdemeanor pleas, the Court found that McGarrh failed to meet his burden to establish that the pleas were not knowing and voluntary due to the absence of court records and conflicting statements in his affidavit (paras 12-19).