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

• Two individuals, Fry and Allen, committed separate murders before 2009 and were sentenced to death. Fry kidnapped, attempted to sexually assault, and killed a woman with a sledgehammer. Allen kidnapped a seventeen-year-old girl, attempted to sexually assault her, and strangled her to death with a rope. Both sought to have their death sentences dismissed, arguing that the sentences were disproportionate in light of the 2009 legislative repeal of the death penalty, which applied only to crimes committed after its enactment (paras 2-6).

Procedural History

• Fry v. Lopez and Allen v. LeMaster: District court denied Petitioners' motions to dismiss their death sentences. The Supreme Court of New Mexico granted interlocutory appeal to consider the statutory validity of Petitioners’ death sentences and whether to reconsider its approach to assessing comparative proportionality under Section 31-20A-4(C)(4) (paras 8-9).

Parties' Submissions

• Petitioners: Argued that their death sentences were disproportionate and violated statutory and constitutional provisions, considering the repeal of the death penalty and its non-application to their cases (para 8).
• Respondents: Contended that the death sentences were constitutional and that the prospective-only application of the repeal did not violate statutory or constitutional provisions.

Legal Issues

• Whether Petitioners’ death sentences are disproportionate in violation of Section 31-20A-4(C)(4), considering the repeal of the death penalty and its prospective-only application (para 3).
• Whether to reconsider the Court's approach to assessing the comparative proportionality of a death sentence under Section 31-20A-4(C)(4) (para 9).

Disposition

• The Supreme Court of New Mexico held that Petitioners’ death sentences were disproportionate under Section 31-20A-4(C)(4) and remanded each case to the district court to impose a sentence of life imprisonment (para 3).

Reasons

• The Court found that the death sentences of Fry and Allen were disproportionate when compared to similar cases where the death penalty was not imposed, considering both the crimes and the defendants. The Court modified its approach to comparative proportionality review, expanding the pool of comparison cases to include factually similar crimes where the jury considered the death penalty, even if different aggravating circumstances were present. The Court concluded that there was no meaningful basis for distinguishing Fry and Allen from many similar cases where the death penalty was not imposed, thus rendering their death sentences statutorily disproportionate. The decision was influenced by the legislative intent to reserve the death penalty for the most heinous crimes and the recognition that the death penalty had been infrequently imposed in New Mexico, indicating a reluctance to use it across all branches of government (paras 13-122).