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 case involves an incident where the victim, previously in a relationship with the defendant, went to the defendant's house to return personal belongings. The defendant asked for help with her car, which the victim refused. The defendant then forced her way into the victim's car, sat on him, and a struggle ensued. During the altercation, the defendant scratched, bit, and pinned the victim down, telling him to "die already" while restraining him for about ten minutes before he managed to escape (paras 2-4).
Procedural History
- District Court, date not specified: The defendant was convicted of false imprisonment and battery against a household member.
Parties' Submissions
- Defendant-Appellant: Argued that the conduct resulting in the convictions was unitary, violating double jeopardy, and that there was insufficient evidence to support the false imprisonment conviction (para 1).
- Plaintiff-Appellee: [Not applicable or not found]
Legal Issues
- Do the convictions for battery against a household member and false imprisonment violate double jeopardy?
- Was there sufficient evidence to support the conviction of false imprisonment?
Disposition
- The New Mexico Court of Appeals affirmed the defendant's convictions for false imprisonment and battery against a household member (para 1).
Reasons
Per Medina, Chief Judge (Ives and Baca JJ. concurring):
The court found that the defendant's conduct was not unitary, as the acts of false imprisonment and battery were separate and distinct. The false imprisonment was complete when the defendant restrained the victim against his will, and the battery involved separate acts of scratching and biting. The court applied the Herron factors to determine the distinctness of the acts and concluded that the defendant's intent and actions were separate for each crime (paras 5-22).
Regarding the sufficiency of evidence for false imprisonment, the court held that the evidence was sufficient to support the conviction. The restraint was not merely incidental to the battery, and the court declined to extend the incidental restraint doctrine from kidnapping to false imprisonment (paras 23-27).