AI Generated Opinion Summaries

Decision Information

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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, Jeffrey Manning, was involved in legal proceedings due to a motion to withdraw his guilty plea, a probation violation, and sentencing as a habitual offender. The case's complexity arose from concurrent proceedings in the same district court case number but before two different judges. The Defendant's probation violation involved allegations of trafficking cocaine and tampering with evidence. During his probation period, evidence of cocaine possession within his residence led to legal actions against him.

Procedural History

  • March 7, 2014, District Court of Bernalillo County: Defendant filed a motion to withdraw his plea before Judge Brown, which was denied on April 8, 2014 (para 3).
  • August 26, 2013: The State filed a motion to revoke Defendant's probation (para 3).
  • July 29, 2014, Judge Jewell: Granted the State's motion, revoking Defendant's probation and sentencing him under habitual offender terms (para 3).
  • August 21, 2014: Defendant filed two separate notices of appeal regarding the order denying his motion to withdraw his plea and the order revoking his probation (para 4).

Parties' Submissions

  • Defendant-Appellant: Argued that the district court erred in denying his motion to withdraw his guilty plea and contended that the evidence did not support a finding of probation violation or justify sentencing as a habitual offender (paras 3-4, 9).
  • Plaintiff-Appellee (State of New Mexico): Maintained that the Defendant violated the terms of his probation and that the sentencing as a habitual offender was justified based on the Defendant's conduct and the evidence presented (paras 6-8).

Legal Issues

  • Whether the district court erred in denying the Defendant's motion to withdraw his guilty plea.
  • Whether the evidence was sufficient to support the district court's finding of a probation violation.
  • Whether the sentencing of the Defendant as a habitual offender was justified.

Disposition

  • The Court of Appeals affirmed the district court's finding of a probation violation and the sentencing of the Defendant as a habitual offender.
  • The Court of Appeals treated the Defendant's motion to withdraw his guilty plea as a habeas corpus petition and transferred this part of the appeal to the Supreme Court (para 1).

Reasons

  • The Court of Appeals, per Judge Stephen G. French, with Judges Michael E. Vigil and J. Miles Hanisee concurring, provided the following reasons:
    The Court determined that the Defendant's motion to withdraw his guilty plea, filed after judgment and sentence, was not directly appealable but should be treated as a habeas corpus petition, leading to its transfer to the Supreme Court (para 5).
    Regarding the probation violation and habitual offender sentencing, the Court found that the district court did not abuse its discretion. The State established the Defendant's probation violation with reasonable certainty, and the district court's decision was supported by evidence presented during multiple hearings (paras 6-11).
    The Court emphasized that it would not reweigh evidence or substitute its judgment for that of the district court, underscoring the limited role of appellate review in such matters (para 9).
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