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 convicted of disorderly conduct and challenged the sentence, specifically the requirement to participate in a misdemeanor compliance program, arguing that her conviction for a petty misdemeanor did not qualify under the statute authorizing such programs.

Procedural History

• Appeal from the District Court of San Juan County, Daylene A. Marsh, District Judge, January 26, 2017.

Parties' Submissions

• Defendant-Appellant: Argued that the sentence requiring participation in a misdemeanor compliance program is invalid for someone convicted of a petty misdemeanor, as the authorizing statute is interpreted to apply only to misdemeanors specified in the Criminal Code.
• Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

• Whether the requirement for the Defendant to participate in a misdemeanor compliance program is valid for a conviction of a petty misdemeanor.

Disposition

• The appeal challenging the sentence was affirmed, allowing the requirement for the Defendant to participate in the misdemeanor compliance program.

Reasons

• Per Michael E. Vigil, J. (Timothy L. Garcia, J., and J. Miles Hanisee, J., concurring): The Court concluded that the term "misdemeanor" includes petty misdemeanors as a subclass, based on historical and legal precedents. The Defendant's argument that the statute authorizing misdemeanor compliance programs does not apply to petty misdemeanors was rejected. The Court held that the Legislature, being presumed to be aware of existing case law, did not need to specify petty misdemeanors if they were not meant to be excluded from such programs. The absence of specific language excluding petty misdemeanors was interpreted as an intent to include them, thus making the portion of the Defendant's sentence requiring participation in the program permissible (paras 2-8).