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 New Year’s Day 2007, Albuquerque Police Department (APD) responded to two accidents near I-40 and Carlisle Blvd. in Albuquerque. The first involved the Defendant's vehicle hitting a light pole, with blood found on the vehicle and multiple shoe prints leading away. The second accident involved a Ford Explorer with the bodies of Linda Gilkey and Nancy Parker Davidson inside, both having been shot. Shoe prints and a gun matching the bullet casings in the Explorer were found near the scene. The Defendant and an acquaintance were later taken into custody from a motel room, where further evidence was collected (paras 2-5).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant: Argued that the warrantless entry into the motel room and the swabbing of his hands for DNA evidence violated his constitutional rights. Also contended that the trial court erred in admitting boots seized from his motel room due to an inadequate chain of custody and claimed insufficient evidence to support his first-degree murder conviction (para 9).
- State: Justified the warrantless searches based on exigent circumstances and argued that the chain of custody for the boots was adequately established. Maintained that there was sufficient evidence to support the Defendant's convictions for first-degree murder (paras 10, 20, 22, 26).
Legal Issues
- Whether the warrantless entry into the Defendant's motel room and the swabbing of his hands for DNA evidence violated his constitutional rights.
- Whether the trial court erred in admitting the boots seized from the Defendant's motel room into evidence.
- Whether there was sufficient evidence to support the Defendant's first-degree murder conviction.
Disposition
- The Supreme Court affirmed the Defendant's convictions, holding that the warrantless searches were justified by exigent circumstances, the trial court did not abuse its discretion in admitting the boots into evidence, and there was sufficient evidence of deliberate intent to support the first-degree murder convictions (para 35).
Reasons
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MAES, Chief Justice, with SERNA, BOSSON, CHÁVEZ, and DANIELS, Justices concurring, found that the warrantless entry into the motel room and the swabbing of the Defendant's hands were justified by exigent circumstances, including the need for swift action to prevent imminent danger or destruction of evidence (paras 10-20). The Court also held that the trial court did not abuse its discretion in admitting the boots into evidence, as the State established an adequate chain of custody (paras 22-26). Finally, the Court concluded that there was substantial evidence of the Defendant's deliberate intent to kill the victims, affirming his first-degree murder convictions (paras 27-34).
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