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

• A child was charged with first degree murder, tampering with evidence, and unlawful possession of a handgun by a person under the age of nineteen. After being detained for approximately eight months, the jury found the child guilty of voluntary manslaughter and lesser charges, but not guilty of being a serious youthful offender. Consequently, the child was adjudicated as a delinquent offender and committed to the New Mexico Children, Youth and Families Department (CYFD) for no longer than two years.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Child-Appellant: Argued that they were entitled to presentence confinement credit for the time spent detained prior to adjudication and disposition, citing NMSA 1978, Section 31-18-15.3(B) (1993). Additionally, claimed entitlement to the same rights as an adult, including predisposition confinement credit, and argued that the disposition was the functional equivalent of a sentence for purposes of awarding presentence confinement credit. Also contended that denial of predisposition confinement credit constituted a denial of due process.
• State of New Mexico (Plaintiff-Appellee): Responded that the child’s written filings and oral argument to the district court did not sufficiently alert the district court to the claimed due process violation, suggesting the issue was not preserved for appeal. Additionally, implied agreement with the district court's conclusion that the applicable statutes do not grant presentence confinement credit in juvenile delinquency dispositions.

Legal Issues

• Whether a child adjudicated as a delinquent offender on a lesser-included offense is entitled to presentence confinement credit against his commitment to the New Mexico Children, Youth and Families Department (CYFD).
• Whether the denial of predisposition confinement credit to the child constitutes a denial of due process.

Disposition

• The Court of Appeals affirmed the district court's decision that the child was not entitled to presentence confinement credit.

Reasons

• The Court, with Judge Timothy L. Garcia authoring the opinion and Judges Jonathan B. Sutin and Cynthia A. Fry concurring, held that the applicable statutes intentionally omit granting presentence confinement credit to juveniles adjudicated as delinquent offenders. The Court referenced the case of State v. Nanco, which addressed similar issues and concluded that the omission of predisposition confinement credit in the statutes was intentional and consistent with the Children’s Code. The Court rejected the child's arguments for entitlement to the same rights as an adult, including predisposition confinement credit, and the argument that the disposition is the functional equivalent of a sentence for purposes of awarding presentence confinement credit. Regarding the due process argument, the Court found it was not preserved for appellate review as the district court was not properly alerted to this argument. The Court also found no basis for reviewing for fundamental error, stating that if a juvenile is entitled to pretrial detention credit, it must be authorized by statute, and there is no such statute. The Court concluded that there was no fundamental unfairness or miscarriage of justice that required addressing the child's due process argument.