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, an elected official, was initially tried in Rio Arriba County for witness intimidation and harboring a felon, which ended in a hung jury and a declared mistrial. The State then successfully moved to change the trial venue to Santa Fe County, citing concerns over the Defendant's influence in the community, extensive media coverage, and unsuitability of the courthouse under COVID-19 restrictions. The Defendant was subsequently convicted on both counts following a jury trial in Santa Fe County.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• State: Argued for a change of venue due to the Defendant's undue influence over the community, biased jury pool from extensive media coverage, and logistical issues with the courthouse in Rio Arriba County under COVID-19 restrictions. Asserted that sufficient evidence supported the Defendant's convictions.
• Defendant: Opposed the change of venue, requested an evidentiary hearing on the matter, and contended that the trial in Rio Arriba County had been fair and impartial. Argued that the convictions were not supported by sufficient evidence and challenged the limitation on cross-examination of witnesses and the failure to replace an allegedly sleeping juror.

Legal Issues

• Whether the district court erred in changing the trial venue from Rio Arriba County to Santa Fe County.
• Whether the district court erred in limiting the Defendant’s cross-examination of two witnesses.
• Whether the district court erred in failing to replace an allegedly sleeping juror.
• Whether the convictions were supported by sufficient evidence.

Disposition

• The Court of Appeals affirmed the Defendant's convictions for witness intimidation and harboring a felon.

Reasons

• HENDERSON, Judge; DUFFY, Judge; IVES, Judge (concurring): The Court found that the district court did not abuse its discretion in changing the venue, as the State provided clear and convincing evidence that a fair trial could not be obtained in Rio Arriba County due to the Defendant's influence, media coverage, and logistical issues. The Court also held that the district court did not err in its rulings on the limitation of cross-examination and the decision not to replace an allegedly sleeping juror, as the Defendant failed to preserve these issues for appellate review. Regarding the sufficiency of the evidence, the Court concluded that there was substantial evidence to support the convictions for witness intimidation and harboring a felon, based on the jury instructions and the evidence presented at trial (paras 2-25).