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 Defendant was convicted of felony battery against a household member after battering the mother of his child among other crimes. This was the Defendant's third conviction of battery against a household member, which led the district court to enhance his conviction to a fourth-degree felony. Additionally, due to a previous separate felony conviction, the district court further enhanced his sentence by one year under the Habitual Offender Act (paras 2, 8).

Procedural History

• State v. Barela, 2019-NMCA-005, 458 P.3d 501: The Court of Appeals, in a divided opinion, distinguished felony battery against a household member from felony DWI and held that the enhanced conviction of felony battery against a household member could serve as an underlying felony under the Habitual Offender Act (para 3).

Parties' Submissions

• Defendant-Petitioner: Argued that felony battery against a household member, being a self-enhancing felony, is not subject to further enhancement under the Habitual Offender Act. This argument was based on the Court's reasoning in State v. Anaya, which held that felony DWI, also a self-enhancing felony, is not subject to the Habitual Offender Act (para 2).
• Plaintiff-Respondent: Contended that the plain language of the statutes at issue unambiguously supports the application of the Habitual Offender Act to felony battery against a household member, thus justifying the sentence enhancement (para 10).

Legal Issues

• Whether a sentence can be enhanced under the Habitual Offender Act when a defendant is convicted of felony battery against a household member (para 1).
• Whether the reasoning in State v. Anaya, regarding felony DWI not being subject to the Habitual Offender Act, applies to felony battery against a household member (paras 2, 15).

Disposition

• The Supreme Court of the State of New Mexico affirmed the Court of Appeals' decision, holding that felony battery against a household member can serve as an underlying felony for purposes of applying the Habitual Offender Act (para 4).

Reasons

• Per BACON, Justice, with MICHAEL E. VIGIL, Chief Justice, BARBARA J. VIGIL, Justice, and DAVID K. THOMSON, Justice concurring:
  The Court concluded that the plain language of Sections 30-3-17(A) and 31-18-17 does not preclude their simultaneous application, thus allowing for the enhancement of the Defendant's sentence under the Habitual Offender Act (paras 6-13).
  The Court distinguished the case from State v. Anaya by noting that felony battery against a household member is a violent crime, unlike felony DWI, and that the Legislature presumably intended for defendants convicted of felony battery against a household member to be subject to the Habitual Offender Act as it applies to other convicted felons (paras 15-20).
  The Court disagreed with the Court of Appeals' reasoning but affirmed its holding, amending the reasoning to focus on the violent nature of felony battery against a household member and the lack of a specific sentencing scheme for such offenses, which supports the application of the Habitual Offender Act (paras 21-23).