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 indicted on charges of criminal sexual penetration and criminal sexual contact of a minor. A status conference set a deadline for pretrial witness interviews, which the State failed to meet, leading the Defendant to file a motion to exclude witnesses not made available by the deadline. The State's motion to extend the deadline was denied due to lack of good cause, and the district court granted the Defendant's motion to exclude the witnesses (paras 2-4).

Procedural History

• District Court, April 2, 2015: Granted Defendant's motion to exclude witnesses for the State's failure to meet the pretrial interview deadline (para 1).
• Court of Appeals of New Mexico, January 24, 2017: Reversed and remanded for consideration of lesser sanctions (para 7).
• Supreme Court of New Mexico, March 16, 2017: Granted Defendant’s petition for writ of certiorari, later quashed it, and remanded the case for further consideration in light of State v. Le Mier (para 7).

Parties' Submissions

• Defendant: Argued that the State failed to make key witnesses available for pretrial interviews by the agreed deadline, which would prejudice the Defendant's ability to prepare for trial (para 4).
• State: Admitted to being "too accommodating with the victim’s family" and failing to schedule some interviews but argued that it attempted to work with the Defendant to set times for interviews. The State also cited an instance where defense counsel failed to appear for a scheduled interview due to a calendaring error (para 5).

Legal Issues

• Whether the district court abused its discretion by excluding the State's witnesses for failing to meet the pretrial interview deadline (para 1).
• Whether the district court properly considered the Harper factors—culpability, prejudice, and the availability of lesser sanctions—when deciding to exclude the witnesses (paras 11-16).

Disposition

• The district court's order granting the Defendant's motion to exclude witnesses was affirmed (para 18).

Reasons

• The Court of Appeals found that the district court did not abuse its discretion in excluding the witnesses. It held that the State was culpable for failing to make witnesses available by the deadline, despite clear instructions and ample time. The failure resulted in prejudice to the Defendant and the court. The district court considered the Harper factors upon limited remand and concluded that exclusion of the witnesses was the most appropriate sanction under the circumstances, especially given the strict timelines and requirements of the judicial district's special calendar rule. The appellate court deferred to the district court's discretion in determining the least severe sanction that would ensure future compliance by the State (paras 13-17).