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 charged with second-degree murder for allegedly shooting her husband. A discovery order required the State to produce copies of computer hard drives from the residence. The Defendant moved to dismiss based on the State's failure to produce these copies. The district court chose to suppress a statement made by the Defendant, instead of dismissing the charges or suppressing the computer evidence, which the Defendant intended to use for self-defense claims (paras 2-3).

Procedural History

• Appeal from the District Court of Bernalillo County, Jacqueline D. Flores, District Judge, May 4, 2016: The district court ordered the exclusion of evidence, effectively excluding a witness.

Parties' Submissions

• Plaintiff-Appellant (State): Argued that the district court's order to exclude a State witness as a sanction for a discovery violation was improper, emphasizing that there was no bad faith or especially culpable conduct by the State, and the suppressed statement was material to the case (paras 2-4).
• Defendant-Appellee: Contended that the suppressed statement was not substantial proof of a fact material to the proceeding and that its inclusion could lead to a "mini-trial" about the couple's relationship. The Defendant also argued that the late discovery did not prevent preparation for trial (para 4).

Legal Issues

• Whether the district court abused its discretion by excluding a witness as a sanction for the State's discovery violation (para 1).
• Whether the suppressed statement was substantial proof of a fact material to the proceeding (para 4).

Disposition

• The Court of Appeals reversed the district court's order excluding evidence and effectively excluding a witness (para 5).

Reasons

• Per Roderick T. Kennedy, J. (Michael E. Vigil, Chief Judge, and Linda M. Vanzi, Judge, concurring): The Court found that the district court abused its discretion. There was no evidence of bad faith or especially culpable conduct by the State. The suppressed statement, "I wish I could kill him again," made by the Defendant, was considered material to the case as it could be interpreted as probative of whether the Defendant acted in self-defense or shot her husband without justification. The Court disagreed with the Defendant's argument that the statement was not substantial proof of a fact material to the proceeding and emphasized that the decision was limited to the exclusion of the witness as a sanction, without expressing an opinion on exclusion on any other basis (paras 2-4).