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 petitioner, Scott Charles, was charged with first-degree criminal sexual penetration (CSP) and second-degree criminal sexual contact with a minor (CSCM). He pleaded guilty to CSCM in exchange for the dismissal of the CSP charge and a recommended three-year sentence. More than a year after his conviction, Charles filed a petition for post-conviction DNA testing, claiming that negative DNA results would have prevented his guilty plea or conviction by proving his innocence (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Petitioner-Appellant: Argued that negative DNA results would have been indisputable evidence of his innocence, which would have prevented his guilty plea or conviction. He contended that without his DNA on the child's body, skin, or clothing, the State could not establish the corpus delicti of the charged crimes (paras 3, 5).
• Respondent-Appellee: The State's specific arguments are not detailed in the decision, but the district court's dismissal of the petition implies a conclusion that the petitioner's arguments did not meet the statutory requirements for post-conviction DNA testing (para 1).

Legal Issues

• Whether the district court erred in dismissing the petitioner's request for post-conviction DNA testing based on the statutory requirements outlined in NMSA 1978, Section 31-1A-2 (2019) (paras 1, 4).

Disposition

• The decision of the district court to dismiss the petition for post-conviction DNA testing was affirmed (para 10).

Reasons

• The Court of Appeals, with Judge Jane B. Yohalem writing the opinion, and concurrence by Chief Judge Jennifer L. Attrep and Judge Shammara H. Henderson, held that the petitioner failed to meet the statutory requirements for post-conviction DNA testing. The court assumed, without deciding, that the petitioner met the first four requirements of Section 31-1A-2(D) but failed to satisfy the fifth requirement—that there is a reasonable probability that the petitioner would not have pled guilty or been found guilty if the DNA testing had been performed prior to the conviction and had produced exculpatory results. The court reasoned that neither DNA evidence nor other physical evidence is required to convict someone of CSCM or CSP under the facts of this case, and that there was sufficient direct and circumstantial evidence to establish the corpus delicti of both crimes without reliance on the petitioner’s confession. Therefore, the absence of DNA evidence would not have created a reasonable probability that the petitioner would not have pleaded guilty or been found guilty (paras 4-9).