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 two counts of trafficking cocaine, a second-degree felony under New Mexico law. He entered into a plea and disposition agreement, pleading nolo contendere to one count in exchange for the dismissal of the second count. The agreement stipulated a nine-year sentence, with all but 24 months suspended, and included probation conditions. The Defendant later violated probation by using cocaine, leading to the revocation of his probation and the imposition of the full nine-year sentence (paras 3-8).
Procedural History
- District Court, March 12, 1993: The Defendant was sentenced to nine years of incarceration, with all but 70 days suspended, and placed on probation for 48 months. The court clarified that a probation violation could result in the imposition of the full nine-year sentence (paras 5-6).
- District Court, April 19, 1993: Following a probation violation, the court revoked the Defendant's probation and imposed the full nine-year sentence (para 8).
- District Court, (date unspecified): The Defendant's motions to enforce the plea agreement and reconsider the sentence were denied (para 10).
Parties' Submissions
- Defendant-Appellant: Argued that the plea agreement limited his incarceration to 24 months, even after a probation violation, and that the trial court violated the agreement by imposing the full nine-year sentence (paras 2, 9-10).
- Plaintiff-Appellee (State): Contended that the plea agreement allowed for a nine-year sentence upon probation violation and that the trial court acted within its discretion. The State also argued that the Defendant reasonably understood the terms of the agreement (paras 11-12).
Legal Issues
- Did the trial court violate the plea agreement by imposing a nine-year sentence following the revocation of the Defendant's probation?
- Should the plea agreement be interpreted to limit the Defendant's incarceration to 24 months, even after a probation violation?
Disposition
- The Court of Appeals vacated the nine-year sentence and remanded the case for resentencing in accordance with the plea agreement, limiting incarceration to 24 months (paras 20-21).
Reasons
Majority Opinion (Per Apodaca J., concurred by Alarid J.)
The majority held that the plea agreement limited the Defendant's incarceration to 24 months, even after a probation violation, as the agreement did not explicitly state otherwise. The court emphasized that ambiguities in plea agreements must be construed against the State, which drafted the agreement. The court rejected the State's argument that extrinsic evidence should determine the Defendant's understanding of the agreement, focusing instead on the written terms. The court concluded that the trial court's imposition of a nine-year sentence violated the plea agreement and ordered resentencing to comply with the 24-month limitation (paras 11-16, 20-21).
Dissenting Opinion (Hartz J.)
Hartz J. dissented, arguing that the plea agreement should be interpreted based on the Defendant's reasonable understanding, which could be informed by extrinsic evidence. He contended that the agreement's language, particularly the clause allowing modification of probation terms upon violation, supported the trial court's authority to impose the full nine-year sentence. Hartz J. also expressed concern about the majority's strict construction against the State and its exclusion of extrinsic evidence, suggesting these approaches could undermine negotiated plea agreements (paras 22-27).