This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
During a traffic stop in Farmington, New Mexico, a deputy observed the Defendant's vehicle swerving within and out of its lane, emitting an odor of alcohol, and the Defendant exhibiting signs of impairment such as slurred speech and bloodshot eyes. The Defendant was arrested for driving while under the influence (DWI) after failing field sobriety tests and refusing a breath test (paras 4-5).
Procedural History
- District Court, June 17, 2021: A mistrial was declared when a juror fell asleep during the proceedings (para 7).
- District Court, October 2022: The Defendant was convicted of DWI (para 8).
Parties' Submissions
- Defendant-Appellant: Argued that the district court violated the New Mexico Constitution by not providing a Navajo language interpreter for a juror, erred in denying the motion to suppress evidence, and that the evidence was insufficient to support the conviction (paras 1-2).
- Plaintiff-Appellee: Contended that the district court's decision not to provide an interpreter was based on a factual finding that the juror's need was not credible, and that the evidence was sufficient to support the conviction (para 1).
Legal Issues
- Did the district court violate the New Mexico Constitution by seating a juror without providing a Navajo language interpreter? (para 1)
- Was the denial of the motion to suppress evidence justified? (para 2)
- Was the evidence sufficient to support the Defendant's conviction? (para 2)
- Did the district court err in denying the motion to exclude the State's expert witness? (para 2)
Disposition
- The conviction was reversed, and the case was remanded for a new trial (para 3).
Reasons
Per Ives J. (Bogardus and Yohalem JJ. concurring):
- The district court erred by not providing a reasoned explanation for denying the juror's request for an interpreter, violating Article VII, Section 3 of the New Mexico Constitution. The court must provide a reasoned explanation on the record when a juror's need for an interpreter is raised (paras 10-20).
- The denial of the motion to suppress was upheld as the deputy had reasonable suspicion to stop the Defendant based on observed traffic violations, supported by substantial evidence (paras 21-30).
- The evidence was deemed sufficient to support the conviction, as the jury could reasonably conclude the Defendant was impaired based on the deputy's observations and the Defendant's admission of drinking (paras 31-36).
- The district court did not abuse its discretion in allowing the State's expert witness to testify, as the Defendant was not prejudiced by the late disclosure, having been prepared for the same witness in the prior trial (paras 38-45).
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