AI Generated Opinion Summaries

Decision Information

Decision Content

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 involved in a larceny case dated July 9, 2015, in Lincoln County and was later incarcerated on August 6, 2015, in Eddy County for an unrelated probation violation. A warrant for the Defendant's arrest in the larceny case was issued on September 2, 2015, with a $5000 unsecured bond noted by Judge Ritter. The Defendant had a first appearance in Lincoln County Magistrate Court on September 23, 2015, and signed a document indicating release on an unsecured bond for the larceny case only. The Defendant entered a guilty plea for the larceny offense on February 19, 2016, and was released from Eddy County Detention Center on March 16, 2016. He turned himself into the Lincoln County Detention Center on March 25, 2016, concerning the larceny case (paras 2-3).

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Plaintiff-Appellant (State): Argued that the presentence confinement credit awarded to the Defendant was excessive and should be recalculated (para 1).
  • Defendant-Appellee: Filed a memorandum in opposition, challenging the State's position but did not dispute the operative facts or provide a specific basis for contention. The Defendant argued that the prosecutor made a judicial admission that he was held continuously due to the larceny case, which he relied upon (paras 3, 5-7).

Legal Issues

  • Whether the presentence confinement credit awarded to the Defendant was excessive and should be recalculated (para 1).
  • Whether the prosecutor's statement at the plea hearing constituted a judicial admission that entitled the Defendant to presentence confinement credit (para 6).

Disposition

  • The Court of Appeals reversed the district court's award of presentence confinement credit to the Defendant and remanded for recalculation (para 10).

Reasons

  • The Court, per Judge Michael E. Vigil, with Judges M. Monica Zamora and J. Miles Hanisee concurring, found that the Defendant was not entitled to the extent of presentence confinement credit awarded because he was released on an unsecured bond for the larceny case, even though he was in custody for a different case during the same period. The Court rejected the Defendant's estoppel argument, stating that the prosecutor's comments during the plea hearing did not constitute a judicial admission that could be reasonably relied upon for entitlement to presentence confinement credit. The Court also noted that the Defendant's memorandum in opposition did not specifically dispute the operative facts or provide a specific basis for contention against the State's position. The Court suggested that upon remand, the district court should explicitly set forth the relevant dates, timeline, and legal principles it deems relevant in its recalculation of the Defendant's presentence confinement credit (paras 4-10).
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