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 brought to the Four Winds Recovery Center's Protective Care Unit (PCU) for protective custody and detoxification. Upon arrival, after being served a cup of soup instead of a tray of food, the Defendant became upset, threw trays on the ground, and during an attempt by Alan Albo, an employee, to restrain him, the Defendant grabbed Albo's neck and injured him. Albo responded by punching the Defendant in the face. The Defendant had not undergone a formal assessment at the time due to intoxication (paras 3-4).

Procedural History

• District Court of San Juan County, Thomas J. Hynes, District Judge: Denied the Defendant's motion to dismiss charges of battery upon a health care worker.

Parties' Submissions

• Defendant-Appellant: Argued that the charges lacked a legally sufficient basis because the employee was not a health care worker employed at a health facility as defined by the relevant statute, contended that the New Mexico Detoxification Reform Act (DRA) precludes prosecution for battery upon a health care worker, and claimed that the statute under which he was charged is unconstitutionally vague and overbroad (paras 1-2, 5).
• Plaintiff-Appellee (State): Responded to the Defendant's contentions, arguing that the DRA does not preclude prosecution, that the employee met the definition of a health care worker employed by a health facility, and that the statute is not unconstitutionally vague or overbroad (para 5).

Legal Issues

• Whether the New Mexico Detoxification Reform Act precludes the State from prosecuting the Defendant for battery upon a health care worker (para 2).
• Whether the employee met the definition of a health care worker employed by a health facility, thereby precluding prosecution under the relevant statute (para 2).
• Whether the statute under which the Defendant was charged is unconstitutionally vague and overbroad (para 2).

Disposition

• The Court of Appeals affirmed the district court’s denial of the Defendant's motion to dismiss (para 34).

Reasons

• Per Timothy L. Garcia, J. (Jonathan B. Sutin, J., Michael E. Vigil, J., concurring):
  The Court held that the DRA does not preclude prosecution for battery upon a health care worker, finding that intoxication does not provide immunity for criminal offenses committed while intoxicated (paras 12-17).
  The Court determined that the employee was a health care worker employed by a health facility at the time of the alleged battery, based on the definitions provided in the statute and the services provided by the PCU (paras 18-29).
  The Court concluded that the statute under which the Defendant was charged is not unconstitutionally vague or overbroad, as it provides sufficient definition to give fair warning of the prohibited conduct and does not encourage arbitrary enforcement (paras 30-32).