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 of three counts of great bodily injury by vehicle (reckless driving counts) and one count of driving while under the influence of intoxicating liquor or drugs (DWI). The case involved an accident where the Defendant's vehicle crashed into a minivan, causing great bodily injury. The Defendant contested the evidence and the jury's findings, particularly challenging the admission of a toxicology report, the sufficiency of evidence, and the restriction of expert testimony among other issues.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by admitting the toxicology report through a witness who did not prepare it or test the blood sample, claimed insufficient evidence for all counts, objected to the admission of hearsay evidence, contested the jury not being given a specific instruction (UJI 14-4512 NMRA), argued against the restriction of his accident reconstruction expert's testimony, and claimed error in the denial of additional presentence confinement credit.
• Plaintiff-Appellee: Conceded that admitting the toxicology report was an error and agreed that the DWI conviction should be reversed and remanded for a new trial. Defended the sufficiency of the evidence for the reckless driving counts and supported the trial court's decisions on the other contested issues.

Legal Issues

• Whether the district court erred by admitting the toxicology report through a witness uninvolved in its preparation or the testing of the blood sample.
• Whether there was sufficient evidence to convict the Defendant for all counts.
• Whether the district court erred in permitting hearsay evidence.
• Whether the district court erred by not giving the jury UJI 14-4512 NMRA.
• Whether the district court erred in restricting the testimony of the Defendant’s accident reconstruction expert.
• Whether the district court erred by denying the Defendant additional presentence confinement credit.

Disposition

• The DWI conviction was reversed, and the case was remanded for a new trial on that charge.
• The convictions for the reckless driving counts were affirmed.

Reasons

• Admission of the Toxicology Report and Results: The court accepted the State's concession that admitting the toxicology report through a witness who did not prepare it or test the blood sample was an error, leading to the reversal of the DWI conviction (paras 4-7).
  Sufficiency of the Evidence: Reckless Driving Counts: The court found sufficient evidence to support the convictions for reckless driving, based on eyewitness testimony and the circumstances of the accident (paras 8-14).
  Hearsay Statements: The court declined to consider the Defendant's argument regarding hearsay evidence due to insufficient specificity and development of the argument (para 15).
  UJI 14-4512’s Definition of “Actual Physical Control”: The court found no error in the district court's decision not to give the jury UJI 14-4512, as it was inapplicable to the case's circumstances (paras 16-19).
  Accident Reconstruction Expert Testimony: The court upheld the district court's decision to restrict the Defendant’s expert witness from testifying about the cause of injuries, as it exceeded his area of expertise (paras 20-23).
  Presentence Confinement: The court presumed the district court did not err in denying additional presentence confinement credit, as the Defendant did not meet the criteria outlined in relevant case law (paras 24-26).