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 indicted on multiple charges, including first-degree child abuse and kidnapping, stemming from an attack on her eight-year-old son. She entered a plea agreement, pleading no contest to second-degree kidnapping, third-degree intentional child abuse, and second-degree attempt to commit intentional child abuse, resulting in a twenty-one-year sentence with nine years suspended. The Defendant later filed an amended petition for writ of habeas corpus, claiming ineffective assistance of counsel, insufficiency of evidence, and racial disproportionality in the grand jury proceedings (paras 2-5).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Plaintiff-Appellant (State of New Mexico): Appealed the district court’s partial grant of Defendant’s amended petition for writ of habeas corpus.
- Defendant-Appellee (Leisha Henderson): Asserted grounds for relief in her amended petition for writ of habeas corpus, including ineffective assistance of counsel, insufficiency of the evidence to support the plea agreement and resulting sentence, and racial disproportionality in the grand jury proceedings (para 5).
Legal Issues
- Whether the district court erred in partially granting Defendant’s amended petition for writ of habeas corpus based on claims of ineffective assistance of counsel and other grounds (para 1).
- Whether the Defendant demonstrated that trial counsel’s performance was deficient and that she suffered prejudice as a result of trial counsel’s deficient performance (paras 9-11).
- Whether the district court erred by limiting the evidentiary hearing to submissions on the issue of ineffective assistance of counsel (paras 7-8, 12-14).
Disposition
- The district court’s order partially granting Defendant’s amended petition for writ of habeas corpus is reversed, and the matter is remanded to the district court for an evidentiary hearing on all issues raised in Defendant’s amended petition requiring the submission of evidence or testimony for their proper resolution (para 18).
Reasons
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Per C. Shannon Bacon, Chief Justice; Michael E. Vigil, Justice; David K. Thomson, Justice; Julie J. Vargas, Justice; Briana H. Zamora, Justice: The Supreme Court of New Mexico reversed the district court's partial grant of the Defendant's amended petition for writ of habeas corpus. The Court found that the district court erred by limiting the evidentiary hearing to submissions on the issue of ineffective assistance of counsel without allowing for the submission of evidence on whether trial counsel advised the Defendant of the possibility to challenge the charge of kidnapping or whether a strategic decision was made not to challenge the charge. The Court also noted that the district court did not provide a sufficient basis for such limitation and failed to adequately identify the basis of its determinations regarding trial counsel's deficient performance and the Defendant's suffered prejudice. Consequently, the case was remanded for an evidentiary hearing on all issues raised in the Defendant’s amended petition that require evidence or testimony for their resolution (paras 7-18).
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