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, Michael Rodriguez, was convicted of first-degree murder for the killing of his girlfriend, Mariana Barnes-Lucero, and tampering with evidence. On the evening of February 29, 2016, the Defendant claimed he was mentally ill and intoxicated, arguing that he was incapable of forming the deliberate intent required for a first-degree murder conviction. The events leading to the murder involved the Defendant consuming alcohol, having an altercation with his grandmother, and later, Barnes-Lucero being found dead at a friend's house where the Defendant had been staying. The Defendant did not dispute taking Barnes-Lucero's life but sought a conviction for second-degree murder instead (paras 4-14).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant-Appellant: Argued that the district court abused its discretion by admitting jail phone calls and pictures of his tattoos, erred in denying multiple defense motions for mistrial during voir dire, and claimed insufficient evidence of deliberate intent to support the first-degree murder conviction (para 2).
- Plaintiff-Appellee: Contended that the jail phone calls and photographs were properly admitted, the motions for mistrial were correctly denied, and there was sufficient evidence to support the conviction for first-degree murder (paras 16-39).
Legal Issues
- Whether the district court abused its discretion by admitting jail phone calls and pictures of the Defendant's tattoos into evidence.
- Whether the district court erred in denying multiple defense motions for mistrial during voir dire.
- Whether there was sufficient evidence of deliberate intent to support the Defendant’s conviction for first-degree murder.
Disposition
- The Supreme Court of New Mexico affirmed the Defendant's convictions of first-degree murder and tampering with evidence (para 40).
Reasons
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PETRA JIMENEZ MAES, Justice (JUDITH K. NAKAMURA, Chief Justice, CHARLES W. DANIELS, Justice, BARBARA J. VIGIL, Justice, GARY L. CLINGMAN, Justice concurring): The court held that the jail phone calls were properly admitted as their probative value was not substantially outweighed by the danger of unfair prejudice. The photographs showing the Defendant's tattoos were relevant to showing a prolonged physical struggle and thus probative of the Defendant's intent. The court found no abuse of discretion in the denial of motions for mistrial during jury selection, as the jurors involved in the discussed instances were excused and there was no evidence that the empaneled jurors were biased. Lastly, the court concluded that there was sufficient evidence for the jury to find that the Defendant killed Barnes-Lucero with the deliberate intention to take away her life, considering the manner of death, the Defendant's actions before and after the crime, and the recorded conversations indicating his awareness and memory of the event (paras 16-39).
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