AI Generated Opinion Summaries

Decision Information

Citations - New Mexico Laws and Court Rules
Rule Set 14 - Uniform Jury Instructions — Criminal - cited by 1,786 documents

Decision Content

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 for DWI (Driving While Intoxicated). During the trial, the jury sought clarification on whether "the slightest impairment" implies even a 1% impairment when driving a motor vehicle. The district court provided the jury with Webster’s dictionary definition of "slight," including its meaning as "small in amount or extent; not great or intense" (para 2).

Procedural History

  • Appeal from the District Court of Doña Ana County, Marci E. Beyer, District Judge.

Parties' Submissions

  • Defendant-Appellant: Contended that the district court erred by providing a dictionary definition to the jury, arguing that this action improperly focused the jury's attention on a single word, "slightest," rather than the broader inquiry of intoxication (paras 2-3, 5-6).
  • Plaintiff-Appellee: [Not applicable or not found]

Legal Issues

  • Whether the district court erred in providing a dictionary definition of "slight" to the jury in response to their query regarding the meaning of "the slightest impairment" in the context of DWI (para 2).

Disposition

  • The Court of Appeals affirmed the conviction, rejecting the Defendant's contention that the district court's provision of the dictionary definition was improper (para 6).

Reasons

  • Per LINDA M. VANZI, Chief Judge (JULIE J. VARGAS, Judge, and DANIEL J. GALLEGOS, Judge, concurring):
    The Court found that the district court's action in providing the dictionary definition was designed to clarify the term "slightest" in response to the jury's specific inquiry and was not improper. This approach is supported by precedent allowing the use of lay dictionaries to discern the ordinary meaning of words used in jury instructions (para 3).
    The Court rejected the Defendant's assertion that reliance on State v. Magby was improper, maintaining that if appellate courts can rely on lay dictionaries for clarifying commonly understood terms in jury instructions, district courts should have similar latitude in addressing jury inquiries (para 4).
    The Court also addressed the Defendant's argument regarding the definition of words not specifically defined in the uniform jury instructions, noting that UJI 14-108 NMRA allows juries to request definitions of otherwise undefined words. The Court declined to impose a limitation that definitions can only be provided if an improper jury argument was made, as suggested by the Defendant (para 5).
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