AI Generated Opinion Summaries

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 case involves the Defendant, Jashon Warren, who was charged with first-degree murder by deliberate killing or, alternatively, by felony murder, shooting at or from a motor vehicle, and possession of a firearm or destructive device by a felon. Before trial, it was agreed that the charge of possession of a firearm or destructive device by a felon would be tried separately due to potential prejudice. During deliberations for the first two counts, the jury was inadvertently given verdict forms for the severed third count, leading to the district court granting a new trial upon discovery of this error (paras 3-9).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Appellant (State): Argued that the district court abused its discretion by granting a new trial without evidence that the jury saw or were influenced by the verdict forms for the severed count (para 11).
• Appellee (Defendant): Moved for a mistrial or, in the alternative, a new trial upon the discovery that the jury had been given verdict forms for a count that had been severed to avoid prejudice (para 6).

Legal Issues

• Whether the district court abused its discretion by granting a new trial based on the inadvertent inclusion of verdict forms for a severed count in the materials given to the jury for deliberation (paras 10-15).

Disposition

• The Supreme Court of New Mexico affirmed the district court's order granting a new trial (para 16).

Reasons

• The Supreme Court, with a unanimous opinion authored by Justice Judith K. Nakamura and concurred by Justices Petra Jimenez Maes, Edward L. Chávez, Charles W. Daniels, and Barbara J. Vigil, held that the district court did not abuse its discretion in granting a new trial. The Court reasoned that the inclusion of the verdict forms for the severed count constituted an "improper communication" between judge and jury, related to the issues of the case, and thus gave rise to a presumption of prejudice which the State failed to rebut. The Court emphasized the importance of ensuring a fair trial and concluded that under the circumstances, the district court's presumption of prejudice and decision to grant a new trial was not an abuse of discretion (paras 11-15).