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

• In August 2007, the Defendant voluntarily approached the sex offender division of the Sheriff’s Department in San Juan County, New Mexico, to register as a sex offender, following a conviction in Florida for lewd and lascivious molestation of a child. He continued to register every ninety days as required until January 2009, when he failed to register. This led to a criminal complaint and his subsequent arrest. Despite registering voluntarily in February 2009 and remaining compliant thereafter, he was tried and found guilty of failing to register as a sex offender.

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by admitting evidence of his Florida sex crime conviction, contended that the State failed to prove he was a sex offender under New Mexico law, and claimed the district court applied a strict liability standard instead of a general intent standard for the requisite mens rea.
• Plaintiff-Appellee: Maintained that the documents from Florida were admissible under several exceptions to the hearsay rule, argued that the documents were self-authenticating, and asserted that the Defendant was a sex offender under New Mexico law, thus required to register under SORNA.

Legal Issues

• Whether the district court erred in admitting evidence of a sex crime conviction from Florida.
• Whether the State failed to prove the Defendant was a sex offender under New Mexico law.
• Whether the district court erred in applying a strict liability standard for the requisite mens rea under SORNA.

Disposition

• The Court of Appeals affirmed the district court's decision, finding the Defendant guilty of failing to register as a sex offender.

Reasons

• The Court of Appeals, per Judge Jonathan B. Sutin, with Judges Cynthia A. Fry and Roderick T. Kennedy concurring, held that the Florida court documents were admissible under Rule 11-803(H) as they constituted public records. The court also found that the documents were self-authenticating under Rule 11-902, negating the need for extrinsic evidence of authenticity. Regarding the Defendant's right to confrontation, the court determined that the Florida court file was not testimonial and was prepared for administrative purposes, not with an eye toward trial. On the sufficiency of evidence, the court found that the State had proven the Defendant was a sex offender under New Mexico law, as his Florida conviction would qualify as a sex offense in New Mexico. Lastly, the court addressed the mens rea requirement under SORNA, concluding that the State had provided sufficient evidence that the Defendant knew of the registration requirement and failed to comply, thus affirming the district court's judgment.