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

In September 2019, a victim advertised a handgun for sale on social media. The defendant drove a friend to the victim's apartment complex for the transaction. During the meeting, a struggle ensued, resulting in the victim being shot and killed. The defendant was accused of aiding and abetting the robbery and murder by holding another individual at knifepoint and shooting at a fleeing vehicle (paras 2-10).

Procedural History

• District Court, June 9, 2025: The defendant was convicted of felony murder, conspiracy to commit armed robbery, shooting at a motor vehicle resulting in great bodily harm, aggravated battery, and aggravated assault. The jury deadlocked on the charge of armed robbery (para 10).

Parties' Submissions

• Appellant: The defendant argued that the evidence was insufficient to support the convictions, the State engaged in prosecutorial misconduct, his due process rights were violated due to the jury's failure to convict on the predicate offense, the jury instructions were improper, and there was cumulative error warranting reversal (para 1).
• Appellee: The State contended that the evidence was sufficient, there was no prosecutorial misconduct, the jury's verdicts were not inconsistent, the jury instructions were proper, and there was no cumulative error.

Legal Issues

• Was the evidence sufficient to support the convictions for felony murder and shooting at a motor vehicle?
• Did the State engage in prosecutorial misconduct during its closing argument?
• Did the jury's failure to convict on the predicate felony for felony murder violate the defendant's due process rights?
• Were the jury instructions improper, leading to juror confusion?
• Was there cumulative error sufficient to warrant reversal?

Disposition

• The Supreme Court of New Mexico affirmed the defendant's convictions for felony murder and shooting at a motor vehicle (para 45).

Reasons

Per Zamora J. (Thomson C.J., Vigil, Bacon, and Vargas JJ. concurring):

• The evidence was sufficient to support the convictions. The jury could reasonably infer that the defendant aided and abetted the killing and intended the killing to occur or knew his actions created a strong probability of death or great bodily harm (paras 12-20).
• The State did not engage in prosecutorial misconduct. The prosecutor's arguments were based on evidence and reasonable inferences (paras 25-31).
• The jury's failure to convict on the predicate felony did not violate due process. Inconsistent verdicts do not warrant reversal if the evidence supports the conviction (paras 32-33).
• The jury instructions were not fundamentally erroneous. The instructions provided a clear path for the jury to convict based on the evidence (paras 34-43).
• There was no cumulative error, as no individual errors were found (para 44).