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

• In 1987, the Defendant was convicted for the murder and armed robbery of a victim, based on evidence including eyewitness testimony, forensic serology, hair and fiber analysis, and shoe print identification. Nearly three decades later, the Defendant sought post-conviction DNA testing of the evidence, which resulted in findings that excluded him as a contributor to the biological material found on the victim's fingernails and clothing.

Procedural History

• State v. Duran, 1988-NMSC-082: The Supreme Court upheld the Defendant's convictions, finding substantial evidence to support the identification of the Defendant as the perpetrator.
• [Not applicable or not found]: Information on decisions issued by lower courts prior to the appeal to the New Mexico Court of Appeals is not provided.

Parties' Submissions

• Appellant: Argued that the district court erred by not setting aside the judgment and sentence based on post-conviction DNA evidence, which excluded him as a contributor to the biological material found on the victim. Additionally, contended that the court denied him due process by not allowing presentation of non-DNA related evidence at the hearing.
• Appellee: Argued that the scope of Section 31-1A-2 is limited to DNA evidence and does not support a broad attack on other scientific evidence and eyewitness testimony from the trial.

Legal Issues

• Whether the district court erred in denying the Defendant's motion to set aside the judgment and sentence based on post-conviction DNA evidence.
• Whether the district court denied the Defendant due process by not allowing him to present non-DNA related evidence at the hearing.

Disposition

• The Court of Appeals reversed the district court’s denial of the Defendant's motion and remanded for reconsideration in light of the standard announced in State v. Hobbs.
• The Court of Appeals concluded that the district court did not err or deprive the Defendant of due process by denying his request to present other non-DNA related evidence at the hearing.

Reasons

• Per BOGARDUS, J. (HANISEE, C.J., and VARGAS, J., concurring):
  The Court of Appeals applied the standard from State v. Hobbs, which requires post-conviction DNA evidence to be material, not merely cumulative or impeaching, and to raise a reasonable probability that the petitioner would not have been found guilty if the DNA testing had been performed prior to the conviction (paras 13-16).
  The Court found that the district court had not yet applied the Hobbs standard to the facts of this case, necessitating a remand for reconsideration (para 16).
  Regarding the presentation of non-DNA related evidence, the Court interpreted Section 31-1A-2 to focus solely on the impact of DNA evidence on the original proceeding, without necessitating a reevaluation of other evidence using current scientific standards (paras 17-22).