This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
- On February 16, 2012, at approximately 2:45 a.m., an Albuquerque Police Department Officer observed the Defendant driving erratically and with a non-functioning license plate lamp. Upon stopping the Defendant, the officer detected an odor of alcohol, bloodshot eyes, and mildly slurred speech, leading to the Defendant's arrest for aggravated DWI and additional charges. The Defendant claimed she was compelled to drive under duress due to feeling unsafe after consuming alcohol at a friend's apartment and deciding to leave for her safety (paras 2-4).
Procedural History
- Metropolitan Court: Convicted the Defendant of aggravated DWI and careless driving.
- District Court of Bernalillo County: Affirmed the metropolitan court's convictions (para 1).
Parties' Submissions
- Defendant-Appellant: Argued that the metropolitan court failed to properly instruct the jury on her duress defense and that the court's misreading of an instruction constituted fundamental error (para 1).
- Plaintiff-Appellee: [Not applicable or not found]
Legal Issues
- Whether the jury instructions as given by the metropolitan court, particularly regarding the Defendant's duress defense, constituted reversible or fundamental error (para 1).
Disposition
- The Court of Appeals affirmed the Defendant's convictions for aggravated DWI and careless driving (para 1).
Reasons
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The Court, with Judge James J. Wechsler writing the opinion, and Judges Jonathan B. Sutin and M. Monica Zamora concurring, held that the jury instructions did not constitute reversible or fundamental error. The Court distinguished between duress and other justification-based defenses, noting that duress does not negate an element of the charged offense but excuses intentional conduct. Therefore, the absence of duress did not need to be added as an essential element of the charged offenses. The Court also found that the metropolitan court's misreading of an instruction during its oral charge to the jury was corrected by the correct written instructions provided to the jury, thus not constituting fundamental error (paras 8-27).
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