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 Defendant was involved in a one-car accident while attempting to flee from physical abuse by her estranged husband. After spending time by the river with a friend to avoid her husband, she found herself being attacked by him in his driveway. In an effort to escape, she drove her car, which eventually crashed through a wall and caught on fire, leading to her arrest for driving under the influence of intoxicating liquor (DWI).

Procedural History

• Metropolitan Court: Convicted the Defendant for DWI (N/A).
• District Court of Bernalillo County: Affirmed the conviction.

Parties' Submissions

• Defendant-Appellant: Argued that she had made a prima facie showing of duress, which should have shifted the burden to the State to prove beyond a reasonable doubt that she was not acting under duress when she drove while alcohol-impaired.
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the Defendant made a prima facie showing of duress sufficient to shift the burden of proof to the State to demonstrate that the Defendant was not acting under duress when she drove while alcohol-impaired.

Disposition

• The Court of Appeals affirmed the conviction, holding that the Defendant failed to make a prima facie showing of the four factors required to establish the defense of duress for a strict liability crime.

Reasons

• Per MICHAEL D. BUSTAMANTE, J. (with JONATHAN B. SUTIN, J., and CYNTHIA A. FRY, J., concurring), the Court found that the Defendant did not satisfy her burden of establishing a prima facie showing of duress. The Court emphasized that it is the defendant's responsibility to provide sufficient evidence that she did not recklessly place herself in a situation that would likely compel her to engage in criminal conduct. The Court also noted that the Defendant's memory loss regarding how she came to be at her husband's house and how the domestic dispute arose did not satisfy the burden of proof required for the defense of duress. The Court declined to redefine the parameters of a duress defense within the context of DWI, affirming the lower courts' decisions.