This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
While being booked into a detention center on a warrant, a small bag containing approximately one gram of methamphetamine was found on the Defendant. The Defendant was subsequently convicted of possession of a controlled substance (methamphetamine) (paras 2-3).
Procedural History
- District Court: The Defendant was convicted of possession of methamphetamine and received a four-year habitual offender enhancement to her sentence (para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the enhancement of her sentence with prior convictions for nonviolent felony drug offenses constitutes cruel and unusual punishment under the Eighth Amendment. Additionally, the Defendant claimed that the district court abused its discretion by stating it had no authority to disregard the mandatory minimum sentence (paras 1, 6, and 11).
- Plaintiff-Appellee: [Not applicable or not found]
Legal Issues
- Whether the enhancement of the Defendant's sentence with prior convictions for nonviolent felony drug offenses constitutes cruel and unusual punishment under the Eighth Amendment.
- Whether the district court abused its discretion by stating it had no authority to disregard the mandatory minimum sentence set forth in the habitual offender enhancement statute.
Disposition
- The New Mexico Court of Appeals affirmed the district court's decision to impose a four-year habitual offender enhancement to the Defendant's sentence (para 1).
Reasons
Per Medina CJ. (Ives and Baca JJ. concurring):
The Court found that the Defendant's argument regarding cruel and unusual punishment was not preserved for appeal because it was not properly raised in the district court. The Defendant did not specifically argue that the four-year enhancement was cruel and unusual punishment, nor did she request the district court to make such a finding (paras 7-10). Additionally, the Court held that the district court did not abuse its discretion because the Defendant failed to request that the court exercise its discretion to consider whether the mandatory enhancement would be cruel and unusual punishment. The Court distinguished the present case from State v. Arrington, where a mandatory sentence was found to be cruel due to the defendant's severe medical needs (paras 11-16).