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

• On December 14, 2010, a car wreck resulted in the death of a female subject, with no eyewitnesses to the crash. Officers found Defendant near the scene, exhibiting signs of alcohol consumption and injuries consistent with being ejected from the vehicle. Defendant initially denied knowledge of the wreck but later stated he was in the car with the deceased, Amber Smith, who he claimed was driving (paras 2-3).

Procedural History

• District Court of Valencia County, February 27, 2015: Charges against Defendant for two counts of vehicular homicide and possession of a controlled substance were dismissed due to the State's inability to prove cause of death without expert testimony (para 5).

Parties' Submissions

• State: Argued that circumstantial evidence was sufficient to establish the corpus delicti of vehicular homicide and that expert testimony was not required as a matter of law to proceed with the case (paras 1, 5, 10).
• Defendant: Contended that the State could not show who was driving or the cause of the accident, arguing the case was based on speculation and lacked sufficient evidence (para 5).

Legal Issues

• Whether expert testimony is required as a matter of law to establish the cause of death in vehicular homicide cases when the State relies on circumstantial evidence (para 1).

Disposition

• The Court of Appeals reversed the district court's order dismissing the charges and remanded for further proceedings (para 19).

Reasons

• The Court of Appeals, with Judge Timothy L. Garcia authoring the opinion, held that circumstantial evidence could be used to establish the elements of vehicular homicide and that expert testimony was not required as a matter of law for the State to proceed with its case. The court found that the State presented sufficient facts in the indictment and at pretrial hearings to circumstantially establish the corpus delicti of vehicular homicide. The decision was concurred by Judges James J. Wechsler and Michael E. Vigil, emphasizing that the district court erred in finding an expert was required as a matter of law in this case (paras 1, 10-18).