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 charged with aggravated driving while under the influence (DWI) as a fifth offense. Before the trial, a plea agreement was proposed by the State, under which the Defendant would plead guilty to a lesser charge of aggravated DWI as a third offense, with other charges being dropped. The Defendant failed to appear at two scheduled hearings for the plea change, subsequently completing a ninety-day inpatient alcohol treatment program, which he believed was a requirement of the plea agreement. Over two years later, the Defendant turned himself in, but the State declared the plea offer void due to his failure to appear at the hearings.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that he substantially complied with the plea agreement by completing the alcohol treatment program and was entitled to specific performance of the plea agreement.
• Plaintiff-Appellee (State of New Mexico): Contended that the Defendant did not meet his burden of demonstrating that the district court erred by denying him specific performance, asserting there was no evidence that completion of a ninety-day treatment program was part of the plea agreement.

Legal Issues

• Whether the district court erred in denying the Defendant's motion to enforce the plea agreement based on his completion of a ninety-day alcohol treatment program.
• Whether the Defendant is entitled to quantum meruit in the form of a ninety-day presentence confinement credit for the time spent in the treatment program.

Disposition

• The district court’s denial of the Defendant’s motion to enforce the plea agreement was affirmed.

Reasons

• The Court, comprising Judges Zachary A. Ives, Jacqueline R. Medina, and Jane B. Yohalem, unanimously affirmed the district court's decision. The Court reasoned that plea bargaining is viewed in contract terms, and a plea bargain is considered an offer until accepted by the court. The Court found no evidence that the Defendant's completion of the alcohol treatment program was part of the plea agreement. It was determined that the Defendant did not fulfill any part of a bargained-for exchange with the prosecution that went beyond agreeing to plead guilty. Therefore, the district court did not err in denying the motion to enforce the plea. Additionally, the Court did not grant the Defendant's request for quantum meruit in the form of a ninety-day presentence confinement credit, as he did not demonstrate that he preserved this issue or that he was entitled to this remedy, nor did he cite any supporting authority for this type of relief (paras 1-12).