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 Defendant was indicted for trafficking methamphetamine. During the case's progression, the State failed to provide contact information for a key witness, chemist Guy Walton, despite listing him as a witness. This omission led to the Defendant's inability to conduct pretrial interviews with Walton, prompting a motion to exclude Walton's testimony due to the State's failure to comply with discovery obligations (paras 2-4).
Procedural History
- District Court of Bernalillo County, November 23, 2015: The court granted Defendant's motion to exclude the State's witness, Guy Walton, due to the State's failure to provide contact information in violation of discovery rules (para 1).
Parties' Submissions
- Defendant: Argued that the State's failure to provide contact information for Guy Walton prevented effective pretrial interviews, violating discovery rules and impairing the Defendant's ability to prepare a defense (para 4).
- State: Contended that it did not violate discovery rules as it did not have Walton's current address post-retirement and that it was not required to retest the drugs. The State also noted that the Defendant never requested a pretrial interview with Walton (paras 3-4).
Legal Issues
- Whether the State's failure to provide contact information for a key witness, Guy Walton, constituted a violation of discovery rules warranting the exclusion of Walton's testimony (para 5).
- Whether the district court properly considered the factors established in State v. Harper and clarified in State v. Le Mier when deciding to exclude the witness (para 6).
Disposition
- The Court of Appeals affirmed the district court's order to exclude Guy Walton's testimony from trial, finding that the State violated discovery rules and that the district court did not abuse its discretion in excluding the witness (para 18).
Reasons
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The Court of Appeals, per Chief Judge Linda M. Vanzi, with Judges J. Miles Hanisee and Henry M. Bohnhoff concurring, held that the State violated discovery rules by failing to provide contact information for Guy Walton, a key witness. The court found that the State had ample time and resources to locate Walton but chose not to. The district court's decision to exclude Walton's testimony was based on the State's violation of discovery obligations, the prejudice to the Defendant, and the court's discretion to impose sanctions for such violations. The appellate court affirmed the exclusion of Walton's testimony, emphasizing the State's culpability, the prejudice to the Defendant, and the consideration of lesser sanctions as per the Harper and Le Mier decisions (paras 9-17).
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