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

• The Defendant was convicted in a bench trial for DWI (first offense), no proof of registration, no proof of insurance, and a red light violation. The evidence against the Defendant included running a red light, the odor of marijuana from the vehicle and the Defendant, admission of smoking marijuana earlier that day, failure to complete field sobriety tests successfully, and a blood test showing marijuana metabolite.

Procedural History

• Appeal from the District Court of Bernalillo County, Neil C. Candelaria, District Judge.

Parties' Submissions

• Plaintiff-Appellee (State of New Mexico): Argued that the evidence presented was sufficient to support the Defendant's conviction for DWI, highlighting the Defendant's failure to perform field sobriety tests, admission of marijuana use, and the presence of marijuana metabolite in his blood.
• Defendant-Appellant (Craig Plyer): Contended that the evidence was insufficient to support his DWI conviction, arguing there was no direct connection between his marijuana use and impaired driving. The Defendant also challenged the probative value of the field sobriety tests and the lack of a drug recognition expert investigation.

Legal Issues

• Whether the evidence was sufficient to support the Defendant's conviction for DWI (first offense).
• Whether the field sobriety tests are probative of impairment by marijuana.
• Whether a drug recognition expert investigation is required to establish a DWI based on drug use.

Disposition

• The Court of Appeals affirmed the Defendant's convictions.

Reasons

• Per Michael D. Bustamante, J. (Cynthia A. Fry, J., and J. Miles Hanisee, J., concurring): The Court held that the evidence was sufficient to support the Defendant's DWI conviction, citing the Defendant's failure to complete field sobriety tests, admission of marijuana use, and the presence of marijuana metabolite in his blood as substantial evidence of impairment. The Court disagreed with the Defendant's assertion that there was no evidence connecting his marijuana use to impaired driving, noting that the combination of the Defendant's actions and the test results provided a reasonable basis for the conviction. The Court also found that the field sobriety tests were probative of impairment and that the lack of a drug recognition expert did not undermine the sufficiency of the evidence. The Court concluded that the Defendant's challenges to the chain of custody and foundation for the blood test results were without merit.