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Facts

  • In 2010, the Defendant was serving a twenty-year prison sentence for second-degree murder and armed robbery related to the death of Donald Chapman. The Defendant filed a pro se motion for immediate release due to the COVID-19 pandemic, citing an extraordinary change in circumstances and his health vulnerabilities that increased his risk for severe outcomes if he contracted the virus. The motion was based on a Supreme Court Order allowing for the waiver of the deadline for filing a motion to reduce a sentence under certain conditions, including the COVID-19 public health emergency (paras 2-3).

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Defendant-Appellant: Argued that the district court was required to hold a hearing and make specific findings of fact and conclusions of law before denying his motion for immediate release due to the COVID-19 pandemic. Contended that his sentence should be reduced because of his health conditions making him particularly susceptible to COVID-19, his status as a model inmate, his educational achievements while incarcerated, and having served 75 percent of his sentence (paras 9-10).
  • Plaintiff-Appellee (State): Responded that the Defendant failed to cite any authority suggesting the district court abused its discretion in denying the motion. Emphasized that the sentence was statutorily authorized, agreed upon, and the minimum term had not yet been served at the time of the reduction request (para 10).

Legal Issues

  • Whether the district court was required to hold a hearing and make specific findings of fact and conclusions of law before denying the Defendant's motion for immediate release due to the COVID-19 pandemic.
  • Whether the Defendant's sentence should be reduced based on the extraordinary circumstances presented by the COVID-19 public health emergency (paras 9-10).

Disposition

  • The Court of Appeals affirmed the district court's order denying the Defendant's motion for immediate release (para 17).

Reasons

  • The Court of Appeals, with Judge Gerald E. Baca writing the opinion, and Judges Jacqueline R. Medina and Jane B. Yohalem concurring, found that the district court did not abuse its discretion by denying the Defendant's motion without a hearing. The Court noted that the Defendant's motion sought a reduction from the basic sentences imposed, which the district court denied, thereby leaving the basic sentences undisturbed. The Court held that the district court was not required to hold a hearing or make a record of mitigating or aggravating circumstances it relied on or to explain its reasons because it did not depart from the basic sentence. The Court also observed that the Defendant failed to show that the district court's decision was unreasonable or arbitrary, and thus, affirmed the district court's decision (paras 9-16).
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