This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- On January 27, 2010, two individuals, Connie Maldonado and David Maldonado, were murdered in their home. Jarlena Anderson, Connie's sister, overheard conversations and a struggle from her room, including threats and the names "Rico" or "Rigo" mentioned by the victims before hearing gunshots and witnessing the aftermath. The State's case against Defendant Rigoberto Rodriguez and his alleged accomplices was largely circumstantial, supported by cell phone records and the testimony of Mario Martinez, who claimed Rodriguez detailed the murders to him (paras 3-5).
Procedural History
- [Not applicable or not found]
Parties' Submissions
- Defendant-Appellant: Argued that the district court erred in admitting cell phone evidence for lack of foundation, claimed insufficient evidence to support convictions, contended the jury was not properly instructed on attempted armed robbery, and argued that three of the four conspiracy convictions should be vacated due to double jeopardy (paras 2, 22).
- Plaintiff-Appellee: Maintained that the cell phone evidence was admissible, argued the evidence was sufficient to support the convictions, and opposed the defendant's claims on jury instruction and double jeopardy (paras 6-21, 23-41).
Legal Issues
- Whether the district court erred in admitting cell phone evidence for lack of foundation.
- Whether there was sufficient evidence to support the defendant's convictions.
- Whether the jury was properly instructed on attempted armed robbery as a predicate felony for felony murder.
- Whether three of the four conspiracy convictions should be vacated due to double jeopardy.
Disposition
- The Supreme Court affirmed all of Defendant’s convictions except for three of his conspiracy convictions, which were vacated due to double jeopardy concerns.
Reasons
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EDWARD L. CHÁVEZ, Justice (with CHARLES W. DANIELS, Chief Justice, PETRA JIMENEZ MAES, Justice, BARBARA J. VIGIL, Justice, JUDITH K. NAKAMURA, Justice concurring): The court found that the district court did not abuse its discretion in admitting cell phone evidence as it was based on previously admitted evidence and testimony (paras 6-21). The court also found sufficient evidence to support the convictions, including circumstantial evidence and witness testimony (paras 23-31). The failure to instruct the jury on attempted armed robbery was not considered fundamental error as the jury convicted the defendant of the completed crime of armed robbery, which served as a predicate felony for felony murder (paras 35-37). Finally, the court agreed that three of the four conspiracy convictions violated double jeopardy principles and should be vacated, leaving only the conviction for conspiracy to commit first-degree murder (paras 38-41).
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