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 driving a truck reported stolen when pursued by Bernalillo County Sheriff’s deputies. During the pursuit, a collision occurred with a motorcyclist, causing severe injuries. The Defendant continued fleeing until his truck was disabled. He was charged with multiple offenses, including great bodily harm by reckless driving and aggravated fleeing of a law enforcement officer. The Defendant admitted to using methamphetamine five hours before the collision, which became a point of contention at trial (paras 3-6).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Appellant: Argued that the district court erred by allowing cross-examination regarding his drug use on the day of the collision, claiming it was irrelevant, prejudicial, and lacked foundational evidence (paras 10, 22).
- Appellee: Contended that the Defendant's drug use was relevant to his perception and credibility as a witness, arguing that it was appropriate for cross-examination and impeachment purposes (paras 12, 18).
Legal Issues
- Whether the district court erred by permitting the State to cross-examine the Defendant about his drug use on the day of the collision.
- Whether the admission of the Defendant's drug use for impeachment purposes was unfairly prejudicial.
- Whether foundational evidence was necessary before the Defendant could be questioned about his drug use (paras 10, 22).
Disposition
- The Court of Appeals affirmed the district court's decision, finding no error in the admission of the Defendant's drug use for impeachment purposes (para 1).
Reasons
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The Court of Appeals, consisting of Judges Kristina Bogardus, J. Miles Hanisee, and Jacqueline R. Medina, held that:Cross-Examination of Defendant Regarding His Drug Use Was Appropriate: The State was entitled to cross-examine the Defendant on matters affecting his credibility, including his drug use, which could alter his perception of the events (paras 12-14).Defendant’s Testimony Was Not Prohibited Character Evidence: The court found the evidence of the Defendant's drug use relevant to his credibility, not as character evidence to show conformity with character (paras 15-17).Defendant’s Testimony Was Not Unfairly Prejudicial: The probative value of the evidence regarding the Defendant's drug use outweighed its prejudicial effect, and the district court took measures to minimize prejudice by referring to methamphetamine only as a “stimulant drug” (paras 18-21).No Foundational Evidence Was Necessary Before Defendant Could be Questioned About His Drug Use: The Defendant had personal knowledge of his drug use and its effects, which did not require foundational testimony from an expert witness (paras 22-23).
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